`NYSCEF DOC. NO. 9
`
`INDEX NO. 707255/2024
`
`RECEIVED NYSCEF: 07/22/2024
`
`SUPREME COURT OF THE STATE OF NEW YORK
`COUNTY OF QUEENS
`---------------------------------------------------------------X
`
`PEDRO TORRES ISPACHE,
`
`Index No.: 707255/2024
`
`Plaintiff,
`
`-against-
`
`STATEMENT OF
`MATERIAL FACTS
`
`ROSCELI NOLASCO RIVERA and
`LEONARDO RIVERA,
`
`Defendants.
`---------------------------------------------------------------X
`
`MICHELLE KARIYEVA, ESQ., an attorney duly licensed to practice law in the Courts
`
`of the State of New York, hereby submits the following Statement of Material Facts pursuant to
`
`Uniform Civil Rule 202.8-8-g (a):
`
`1. On December 11, 2023, at approximately 7:00 A.M., the Plaintiff, Pedro Torres Ispache,
`
`was involved in a motor vehicle accident.
`
`2. The accident occurred on Hempstead Avenue and Springfield Boulevard, in the County
`
`of Kings, while the Plaintiff was crossing the street.
`
`3. More specifically, the Plaintiff was crossing the street using the pedestrian crosswalk and
`
`with the walking signal in the Plaintiff’s favor.
`
`4. The Plaintiff looked both ways for oncoming vehicles.
`
`5. Upon seeing no vehicles, the Plaintiff proceeded to traverse across the street, until he was
`
`hit by the Defendant’s vehicle, suddenly and without warning.
`
`6. When the police arrived at the scene of the accident, the Defendant driver admitted to
`
`hitting the Plaintiff with her vehicle.
`
`1 of 2
`
`
`
`FILED: QUEENS COUNTY CLERK 07/22/2024 11:30 AM
`NYSCEF DOC. NO. 9
`
`INDEX NO. 707255/2024
`
`RECEIVED NYSCEF: 07/22/2024
`
`7. On the above date and time,
`
`the 2018 Nissan motor vehicle bearing New York
`
`registration number KSR6709, was operated by Defendant, Rosceli Nolasco Rivera, and
`
`owned by Defendant, Leonardo Rivera.
`
`8. The Defendant owner, Leonardo Rivera, gave the Defendant operator, Rosceli Nolasco
`
`Rivera, permission to operate said vehicle.
`
`9. The Defendant owner, Leonardo Rivera, gave the Defendant operator, Rosceli Nolasco
`
`Rivera, express consent to operate said vehicle.
`
`10. The Defendant owner, Leonardo Rivera, gave the Defendant operator, Rosceli Nolasco
`
`Rivera, implied consent to operate said vehicle.
`
`Dated: Queens, New York
`July 22, 2024
`
`Respectfully submitted,
`
`_________________________
`Raytsin Law Firm, P.C.
`By: Michelle Kariyeva, Esq.
`Attorneys for Plaintiff
`221-10 Jamaica Ave., Suite 108
`Queens Village, New York 11428
`(718) 355-9797
`
`2 of 2
`
`
Accessing this document will incur an additional charge of $.
After purchase, you can access this document again without charge.
Accept $ Charge
Still Working On It
This document is taking longer than usual to download. This can happen if we need to contact the court directly to obtain the document and their servers are running slowly.
Give it another minute or two to complete, and then try the refresh button.
A few More Minutes ... Still Working
It can take up to 5 minutes for us to download a document if the court servers are running slowly.
Thank you for your continued patience.
This document could not be displayed.
We could not find this document within its docket. Please go back to the docket page and check the link. If that does not work, go back to the docket and refresh it to pull the newest information.
Your account does not support viewing this document.
You need a Paid Account to view this document. Click here to change your account type.
Your account does not support viewing this document.
Set your membership
status to view this document.
With a Docket Alarm membership, you'll
get a whole lot more, including:
- Up-to-date information for this case.
- Email alerts whenever there is an update.
- Full text search for other cases.
- Get email alerts whenever a new case matches your search.
One Moment Please
The filing “” is large (MB) and is being downloaded.
Please refresh this page in a few minutes to see if the filing has been downloaded. The filing will also be emailed to you when the download completes.
Your document is on its way!
If you do not receive the document in five minutes, contact support at support@docketalarm.com.
Sealed Document
We are unable to display this document, it may be under a court ordered seal.
If you have proper credentials to access the file, you may proceed directly to the court's system using your government issued username and password.
Access Government Site
