`NYSCEF DOC. NO. 20
`
`INDEX NO. 158058/2019
`
`RECEIVED NYSCEF: 02/28/2022
`
`SUPREME
`COUNTY
`---------------
`
`OF THE STATE
`COURT
`OF NEW YORK
`---------------
`
`CHRISTOPHER
`
`C. RICCIARDELLI,
`
`OF NEW YORK
`
`---------------------------X
`
`INDEX
`
`NO.:
`
`158058/2019
`
`Plaintiff
`
`'
`
`AFFIRMATION
`
`OF GOOD
`
`FAITH
`
`-against-
`
`NAGPAL
`
`RAKESH
`
`and M.P.J.
`
`CAB
`
`CORP.,
`
`-----------
`
`Defendants.
`-------------------------X
`
`DANIELA
`
`F. HENRIQUES,
`
`ESQ.,
`
`an
`
`attorney
`
`duly
`
`licensed
`
`to practice
`
`law
`
`before
`
`the
`
`Courts
`
`of
`
`the
`
`State
`
`of New York,
`
`hereby
`
`affirms
`
`the
`
`truth
`
`of
`
`the
`
`following
`
`statements
`
`under
`
`the
`
`penalty
`
`of perjury:
`
`1.
`
`That
`
`I
`
`am a member
`
`of
`
`LEAV
`
`& STElNBERG,
`
`LLP,
`
`attorneys
`
`for
`
`plaintiff
`
`CHRISTOPHER
`
`C. RICCIARDELLI
`
`and as such,
`
`am fully
`
`familiar
`
`with
`
`the facts
`
`and circumstances
`
`of
`
`this
`
`action.
`
`The
`
`source
`
`of your
`
`affirmants'
`
`knowledge
`
`is a file maintained
`
`by my office
`
`and
`
`your
`
`affirmants'
`
`personal
`
`work
`
`thereupon.
`
`2.
`
`I submit
`
`this
`
`affirmation
`
`pursuant
`
`to the New York
`
`Supreme
`
`Court
`
`rules,
`
`specifically
`
`Uniform
`
`Court
`
`Rule
`
`Section
`
`202.7.
`
`3.
`
`This
`
`affirmation
`
`is
`
`submitted
`
`in
`
`support
`
`of
`
`the
`
`instant
`
`motion
`
`to
`
`preclude
`
`defendants
`
`NAGPAL
`
`RAKESH
`
`and M.P.J.
`
`CAB CORP.
`
`from
`
`offering
`
`testimony
`
`at
`
`trial
`
`and
`
`from
`
`offering
`
`any
`
`affidavits
`
`as to the facts
`
`and
`
`circumstances
`
`of
`
`the happening
`
`of
`
`this
`
`accident
`
`in a summary
`
`judgment
`
`motion
`
`due to her willful
`
`failure
`
`to appear
`
`for Court
`
`directed
`
`deposition
`
`or
`
`in turn
`
`schedule
`
`the
`
`same.
`
`4.
`
`Your
`
`affinnañts'
`
`law firm has attempted,
`
`in good
`
`faith,
`
`to resolve
`
`the issues
`
`raised
`
`the
`
`by
`
`instant
`
`motion
`
`(phone
`
`calls
`
`between
`
`the
`
`calendar
`
`clerks
`
`of both
`
`firms
`
`and/or
`
`
`correspondence
`
`with
`
`defense
`
`counsel),
`
`without
`
`the
`
`intervention
`
`of
`
`the Court,
`
`but
`
`despite
`
`these
`
`attempts,
`
`the
`
`issues
`
`have
`
`not
`
`been
`
`resolved.
`
`1 of 2
`
`
`
`FILED: NEW YORK COUNTY CLERK 02/28/2022 10:58 AM
`NYSCEF DOC. NO. 20
`
`INDEX NO. 158058/2019
`
`RECEIVED NYSCEF: 02/28/2022
`
`5.
`
`Your
`
`affirmant
`
`believes
`
`the
`
`
`correspondence
`
`referenced
`
`above
`
`and
`
`the
`
`various
`
`postponed
`
`deposition
`
`dates
`
`for
`
`defendants
`
`NAGPAL
`
`RAKESH
`
`and
`
`M.P.J.
`
`CAB
`
`CORP.
`
`(depositions
`
`scheduled
`
`for
`
`September
`
`10, 2021;
`
`depositions
`
`re-scheduled
`
`again
`
`for December
`
`21,
`
`2021
`
`and
`
`depositions
`
`re-scheduled
`
`again
`
`for
`
`February
`
`23,
`
`2022;
`
`as of
`
`today,
`
`the
`
`deposition
`
`of
`
`faith
`
`effort
`
`to
`
`resolve
`
`our
`
`defendants
`
`was
`
`adjourned
`
`without
`
`date)
`
`serve
`
`as
`
`the
`
`necessary
`
`good
`
`discovery
`
`disputes
`
`as per Administrative
`
`Order
`
`270/20
`
`Section
`
`202.20f.
`
`6.
`
`As
`
`a result
`
`of
`
`the forgoing,
`
`the instant
`
`application
`
`is necessary.
`
`WHEREFORE,
`
`plaintiff
`
`respectfully
`
`request
`
`that
`
`this Court
`
`entertain
`
`the issues
`
`raised
`
`in the
`
`annexed
`
`motion
`
`and that
`
`said motion
`
`be placed
`
`on the IAS Motion
`
`Support
`
`calendar
`
`solution.
`
`Dated:
`
`New York,
`February
`
`New York
`2022
`
`28,
`
`D
`
`ELA
`
`. HENRIQ
`
`,
`
`SQ.
`
`2 of 2
`
`
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