FILED: CHEMUNG COUNTY CLERK 08/24/2023 10:25 AM
`NYSCEF DOC. NO. 10
`
`INDEX NO. 2023-5539
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`RECEIVED NYSCEF: 08/24/2023
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`
`
`
`
`Plaintiff(s),
`
`
`Index No.: 2023-5539
`
`
`NOTICE TO ADMIT
`
`
`
`
`
`
`
`
`
`
`-against-
`
`SUPREME COURT OF THE STATE OF NEW YORK
`COUNTY OF CHEMUNG
`-------------------------------------------------------------------------X
`CAPREECE MOORE,
`
`
`
`
`
`
`
`
`
`LESHA P. MASSOUP, DUKE HUR, J. B. HUNT
`TRANSPORT, INC., COSTCO WHOLESALE
`CORPORATION and
`
`Defendant(s).
`
`
`
`
`
`-------------------------------------------------------------------------X
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`
`
`
`PLEASE TAKE NOTICE that pursuant to Section 3123 of the CPLR, you are hereby
`
`requested to furnish to the undersigned, within twenty (20) days after the service of this notice, a
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`written admission of the truth of the following matters of fact:
`
`1.
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`That on November 12, 2021, and upon information and belief, the defendant, J.
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`B. HUNT TRANSPORT, INC., owned a certain 2022 International LT625 truck, bearing
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`Indiana State registration number, 3058781.
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`
`
`2.
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`That on November 12, 2021, and upon information and belief, the defendant, J.
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`B. HUNT TRANSPORT, INC., was the title owner of a certain 2022 International LT625 truck,
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`bearing Indiana State registration number, 3058781.
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`
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`3.
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`That on November 12, 2021, and upon information and belief, the defendant, J.
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`B. HUNT TRANSPORT, INC., was the register owner of a certain 2022 International LT625
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`truck, bearing Indiana State registration number, 3058781.
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`1 of 4
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`NYSCEF DOC. NO. 10
`
`INDEX NO. 2023-5539
`
`RECEIVED NYSCEF: 08/24/2023
`
`
`
`
`
`Plaintiff(s),
`
`
`Index No.: 2023-5539
`
`
`NOTICE TO ADMIT
`
`
`
`
`
`
`
`
`
`
`-against-
`
`SUPREME COURT OF THE STATE OF NEW YORK
`COUNTY OF CHEMUNG
`-------------------------------------------------------------------------X
`CAPREECE MOORE,
`
`
`
`
`
`
`
`
`
`LESHA P. MASSOUP, DUKE HUR, J. B. HUNT
`TRANSPORT, INC., COSTCO WHOLESALE
`CORPORATION and
`
`Defendant(s).
`
`
`
`
`
`-------------------------------------------------------------------------X
`
`
`
`
`PLEASE TAKE NOTICE that pursuant to Section 3123 of the CPLR, you are hereby
`
`requested to furnish to the undersigned, within twenty (20) days after the service of this notice, a
`
`written admission of the truth of the following matters of fact:
`
`1.
`
`That on November 12, 2021, and upon information and belief, the defendant, J.
`
`B. HUNT TRANSPORT, INC., owned a certain 2022 International LT625 truck, bearing
`
`Indiana State registration number, 3058781.
`
`
`
`2.
`
`That on November 12, 2021, and upon information and belief, the defendant, J.
`
`B. HUNT TRANSPORT, INC., was the title owner of a certain 2022 International LT625 truck,
`
`bearing Indiana State registration number, 3058781.
`
`
`
`3.
`
`That on November 12, 2021, and upon information and belief, the defendant, J.
`
`B. HUNT TRANSPORT, INC., was the register owner of a certain 2022 International LT625
`
`truck, bearing Indiana State registration number, 3058781.
`
`1 of 4
`
`
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`FILED: CHEMUNG COUNTY CLERK 08/24/2023 10:25 AM
`NYSCEF DOC. NO. 10
`
`INDEX NO. 2023-5539
`
`RECEIVED NYSCEF: 08/24/2023
`
`
`
`4.
`
`That on November 12, 2021, and upon information and belief, the defendant, J.
`
`B. HUNT TRANSPORT, INC., owned a certain 2022 International LT625 truck, bearing a
`
`vehicle identification number, 3HSDZTZRXNN565422.
`
`
`
`5.
`
`That on November 12, 2021, and upon information and belief, the defendant, J.
`
`B. HUNT TRANSPORT, INC., was the title owner of a certain 2022 International LT625 truck,
`
`bearing a vehicle identification number, 3HSDZTZRXNN565422.
`
`
`
`6.
`
`That on November 12, 2021, and upon information and belief, the defendant, J.
`
`B. HUNT TRANSPORT, INC., was the register owner of a certain 2022 International LT625
`
`truck, bearing a vehicle identification number, 3HSDZTZRXNN565422.
`
`
`
`7.
`
`That on November 12, 2021, and upon information and belief, the defendant, J.
`
`B. HUNT TRANSPORT, INC., was lessor of a certain 2022 International LT625 truck, bearing
`
`Indiana State registration number, 3058781.
`
`
`
`8.
`
`That on November 12, 2021, and upon information and belief, the defendant, J.
`
`B. HUNT TRANSPORT, INC., was lessee of a certain 2022 International LT625 truck, bearing
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`Indiana State registration number, 3058781.
`
`
`
`9.
`
`That on November 12, 2021, and upon information and belief, the defendant,
`
`DUK HUR, i/s/h/ as DUKE HUR, operated a certain 2022 International LT625 truck, bearing
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`Indiana State registration number, 3058781.
`
`
`
`10.
`
`That on November 12, 2021, and upon information and belief, the defendant,
`
`DUK HUR, i/s/h/ as DUKE HUR, operated a certain 2022 International LT625 truck, bearing a
`
`vehicle identification number, 3HSDZTZRXNN565422.
`
`
`
`11.
`
`That on November 12, 2021, and upon information and belief, the defendant,
`
`DUK HUR, i/s/h/ as DUKE HUR, leased a certain 2022 International LT625 truck, bearing
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`Indiana State registration number, 3058781.
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`2 of 4
`
`
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`FILED: CHEMUNG COUNTY CLERK 08/24/2023 10:25 AM
`NYSCEF DOC. NO. 10
`
`INDEX NO. 2023-5539
`
`RECEIVED NYSCEF: 08/24/2023
`
`
`
`12.
`
`That on November 12, 2021, and upon information and belief, the defendant,
`
`DUK HUR, i/s/h/ as DUKE HUR, leased a certain 2022 International LT625 truck, bearing a
`
`vehicle identification number, 3HSDZTZRXNN565422.
`
`
`
`13.
`
`That on November 12, 2021, and upon information and belief, the defendant,
`
`DUK HUR, i/s/h/ as DUKE HUR, operated a certain 2022 International LT625 truck, bearing
`
`Indiana State registration number, 3058781, with the knowledge, permission and consent of the
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`defendant, J. B. HUNT TRANSPORT, INC.
`
`
`
`14.
`
`That on November 12, 2021, and upon information and belief, the defendant,
`
`DUK HUR, i/s/h/ as DUKE HUR, operated a certain 2022 International LT625 truck, bearing a
`
`vehicle identification number, 3HSDZTZRXNN565422, with the knowledge, permission and
`
`consent of the defendant, J. B. HUNT TRANSPORT, INC.
`
`
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`15.
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`That on November 12, 2021, and upon information and belief, the defendant,
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`DUKE HUR, was an employee of the defendant, J. B. HUNT TRANSPORT, INC.
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`
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`16.
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`That at all times hereinafter alleged, and upon information and belief, the defendant,
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`DUKE HUR, was acting within the course of his employment when he was operating a certain
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`2022 International LT625 truck, bearing Indiana State registration number, 3058781.
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`
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`17.
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`That at all times hereinafter alleged, and upon information and belief, the defendant,
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`DUKE HUR, was acting within the course of his employment when he was operating a certain
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`2022 International LT625 truck, bearing a vehicle identification number,
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`3HSDZTZRXNN565422.
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`PLEASE TAKE NOTICE, that each of the matters of which an admission is requested
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`shall be deemed admitted unless within twenty (20) days after service herein, (or within such further
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`time as the court may allow), the party defendants serve upon the demanding party's attorney's
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`office a sworn statement either denying specifically the matters of which an admission is requested
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`3 of 4
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`
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`FILED: CHEMUNG COUNTY CLERK 08/24/2023 10:25 AM
`NYSCEF DOC. NO. 10
`
`INDEX NO. 2023-5539
`
`RECEIVED NYSCEF: 08/24/2023
`
`or setting forth in detail the reasons why he cannot truthfully either admit or deny those matters. If
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`any matters of which an admission is requested cannot be fairly admitted without some material
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`qualification or explanation, or if the matters constitute a trade secret or such party would be
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`privileged or disqualified from testifying as a witness concerning them, such party may, in lieu of a
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`denial or statement, serve a sworn statement setting forth in detail his claim and, if the claim is that
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`the matters cannot be fairly admitted without some material qualification or explanation, admitting
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`the matters with such qualification or explanation.
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`New York, New York
`August 24, 2023
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`Dated:
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`
`
`
`
`Yours, etc.
`
`Jason L. Paris
`___________________________
`JASON L. PARIS, ESQ.
`THE PARIS LAW GROUP, P.C.
`Attorneys for Plaintiff
`CAPREECE MOORE
`60 East 42nd Street, Suite 4000
`New York, NY 10165
`212-970-8754
`
`
`
`TO:
`
`
`
`
`WEBER GALLAGHER SIMPSON STAPLETON FIRES & NEWBY LLP
`Attorneys for Defendants
`Duke Hur and J.B. Hunt Transport, Inc.
`1500 Broadway, Suite 2401
`New York, New York 10036
`(929) 342-6000
`
`4 of 4
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