`NYSCEF DOC. NO. 14
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`INDEX NO. 2023-5539
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`RECEIVED NYSCEF: 09/06/2023
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`Plaintiff(s),
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`Index No.: 2023-5539
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`NOTICE TO ADMIT
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`-against-
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`SUPREME COURT OF THE STATE OF NEW YORK
`COUNTY OF CHEMUNG
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`CAPREECE MOORE,
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`LESHA P. MASSOUP, DUKE HUR, J. B. HUNT
`TRANSPORT, INC. and COSTCO WHOLESALE
`CORPORATION,
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`Defendant(s).
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`PLEASE TAKE NOTICE that pursuant to Section 3123 of the CPLR, you are hereby
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`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:
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`1.
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`That on November 12, 2021, and upon information and belief, the defendant,
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`COSTCO WHOLESALE CORPORATION, owned a certain 2022 International LT625 truck,
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`bearing 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,
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`COSTCO WHOLESALE CORPORATION, was the title owner of a certain 2022
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`International LT625 truck, bearing Indiana State registration number, 3058781.
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`3.
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`That on November 12, 2021, and upon information and belief, the defendant,
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`COSTCO WHOLESALE CORPORATION, was the register owner of a certain 2022
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`International LT625 truck, bearing Indiana State registration number, 3058781.
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`1 of 4
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`FILED: CHEMUNG COUNTY CLERK 09/06/2023 02:24 PM
`NYSCEF DOC. NO. 14
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`INDEX NO. 2023-5539
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`RECEIVED NYSCEF: 09/06/2023
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`4.
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`That on November 12, 2021, and upon information and belief, the defendant,
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`COSTCO WHOLESALE CORPORATION, owned a certain 2022 International LT625 truck,
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`bearing a vehicle identification number, 3HSDZTZRXNN565422.
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`5.
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`That on November 12, 2021, and upon information and belief, the defendant,
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`COSTCO WHOLESALE CORPORATION, was the title owner of a certain 2022
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`International LT625 truck, bearing a vehicle identification number, 3HSDZTZRXNN565422.
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`6.
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`That on November 12, 2021, and upon information and belief, the defendant,
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`COSTCO WHOLESALE CORPORATION, was the register owner of a certain 2022
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`International LT625 truck, bearing a vehicle identification number, 3HSDZTZRXNN565422.
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`7.
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`That on November 12, 2021, and upon information and belief, the defendant,
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`COSTCO WHOLESALE CORPORATION, was lessor of a certain 2022 International LT625
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`truck, bearing Indiana State registration number, 3058781.
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`8.
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`That on November 12, 2021, and upon information and belief, the defendant
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`COSTCO WHOLESALE CORPORATION, was lessee of a certain 2022 International LT625
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`truck, bearing Indiana State registration number, 3058781.
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`9.
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`That on November 12, 2021, and upon information and belief, the defendant
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`COSTCO WHOLESALE CORPORATION, owner of a certain 2018 Wabash National Trailer
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`bearing New Jersey State registration number, TSU65V.
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`10.
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`That on November 12, 2021, and upon information and belief, the defendant
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`COSTCO WHOLESALE CORPORATION, was the title owner of a certain 2018 Wabash
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`National Trailer bearing New Jersey State registration number, TSU65V.
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`11.
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`That on November 12, 2021, and upon information and belief, the defendant
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`COSTCO WHOLESALE CORPORATION, was the register owner of a certain 2018 Wabash
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`National Trailer bearing New Jersey State registration number, TSU65V.
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`2 of 4
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`FILED: CHEMUNG COUNTY CLERK 09/06/2023 02:24 PM
`NYSCEF DOC. NO. 14
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`INDEX NO. 2023-5539
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`RECEIVED NYSCEF: 09/06/2023
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`12.
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`That on November 12, 2021, and upon information and belief, the defendant
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`COSTCO WHOLESALE CORPORATION, was the lessor of a certain 2018 Wabash National
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`Trailer bearing New Jersey State registration number, TSU65V.
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`13.
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`That on November 12, 2021, and upon information and belief, the defendant
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`COSTCO WHOLESALE CORPORATION, was the lessee of a certain 2018 Wabash National
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`Trailer bearing New Jersey State registration number, TSU65V.
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`14.
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`That on November 12, 2021, and upon information and belief, the defendant,
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`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, with the knowledge, permission and consent of the
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`defendant, COSTCO WHOLESALE CORPORATION.
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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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`DUK HUR, i/s/h/ as DUKE HUR, operated a certain 2022 International LT625 truck, bearing a
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`vehicle identification number, 3HSDZTZRXNN565422, with the knowledge, permission and
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`consent of the defendant, COSTCO WHOLESALE CORPORATION.
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`16.
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`That on November 12, 2021, and upon information and belief, the defendant,
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`DUK HUR, i/s/h/ as DUKE HUR, operated a certain 2018 Wabash National Trailer bearing
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`New Jersey State registration number, TSU65V, with the knowledge, permission and consent of
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`the defendant, COSTCO WHOLESALE CORPORATION.
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`17.
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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, COSTCO WHOLESALE CORPORATION.
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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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`FILED: CHEMUNG COUNTY CLERK 09/06/2023 02:24 PM
`NYSCEF DOC. NO. 14
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`INDEX NO. 2023-5539
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`RECEIVED NYSCEF: 09/06/2023
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`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
`September 6, 2023
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`Dated:
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`Yours, etc.
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`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
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`TO:
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`WEBER GALLAGHER SIMPSON STAPLETON FIRES & NEWBY LLP
`Attorneys for Defendants
`DUKE HUR,
`J. B. HUNT TRANSPORT, INC.
`and COSTCO WHOLESALE CORPORATION
`1500 Broadway, Suite 2401
`New York, New York 10036
`(929) 342-6000
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`4 of 4
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