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FILED: CHEMUNG COUNTY CLERK 04/02/2024 09:34 AM
`NYSCEF DOC. NO. 60
`
`INDEX NO. 2023-5539
`
`RECEIVED NYSCEF: 04/02/2024
`
`
`
`Index No.: 2023-5539
`
`
`AFFIRMATION IN
`OPPOSITION
`
`
`
`
`Plaintiff(s),
`
`
`
`
`
`-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. and COSTCO WHOLESALE
`CORPORATION,
`
`Defendant(s).
`
`
`
`
`
`----------------------------------------------------------------------X
`
`
`JASON PARIS, an attorney duly admitted to practice law in the State of New York,
`hereby affirms and states the following under the penalty of perjury:
`
`I am a member of The Paris Law Group, PC, attorneys for plaintiff herein, and as
`1.
`such I am fully familiar with the facts and circumstances herein.
`
`I make this affirmation in opposition to defendants, DUKE HUR, J. B. HUNT
`2.
`TRANSPORT, INC. and COSTCO WHOLESALE CORPORATION’s motion seeking for an
`Order extending the deadlines set forth in this Court’s Preliminary Conference Order, dated
`September 29, 2023, by 30 days.
`
`This action is to recover damages for the personal injuries sustained by plaintiff,
`3.
`CAPREECE MOORE, on November 12, 2021 as a result of defendants’ negligence.
`4.
`The plaintiff, CAPREECE MOORE, joins in the arguments set forth by attorneys for
`Defendants, DUKE HUR, J. B. HUNT TRANSPORT, INC. and COSTCO WHOLESALE
`CORPORATION.
`WHEREFORE, it is respectfully requested that this Court issue an Order granting
`
`
`
`
`
`1 of 2
`
`

`

`FILED: CHEMUNG COUNTY CLERK 04/02/2024 09:34 AM
`NYSCEF DOC. NO. 60
`
`INDEX NO. 2023-5539
`
`RECEIVED NYSCEF: 04/02/2024
`
`defendants, DUKE HUR, J. B. HUNT TRANSPORT, INC. and COSTCO WHOLESALE
`CORPORATION’s motion in their entirety, and for such other and further relief as this Court deems
`just and proper.
`
`Dated:
`
`
`New York, New York
`April 2, 2024
`
`
`
`
`
`
`
`
`
`
`
`
`
`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
`
`
`
`
`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
`
`Law Office of Keith D. Miller
`Attorneys for Defendant
`LESHA P. MASSOUP
`1000 7th North Street, Suite 120
`Liverpool, NY 13088
`315-701-5768
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`TO:
`
`
`
`
`
`
`2 of 2
`
`

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