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CHARTAYNE DUNNING v. ELRAC, LLC D/B/A ENTERPRISE RENT-A-CAR et al

Docket 160542/2024, New York State, New York County, Supreme Court (Nov. 12, 2024)
Case TypeTorts - Motor Vehicle
TagsTort, Civil, Vehicle
Plaintiff Chartayne Dunning
Defendant ELRAC, LLC D/B/A ENTERPRISE RENT-A-CAR
Defendant Patricia Wilson
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ANSWER

Document CHARTAYNE DUNNING v. ELRAC, LLC D/B/A ENTERPRISE RENT-A-CAR et al, 160542/2024, 2 (N.Y. Sup. Ct., New York County Jan. 9, 2025)
If none exist, state so.
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SUMMONS + COMPLAINT SUMMONS + COMPLAINT

Document CHARTAYNE DUNNING v. ELRAC, LLC D/B/A ENTERPRISE RENT-A-CAR et al, 160542/2024, 1 (N.Y. Sup. Ct., New York County Nov. 12, 2024)
Plaintiff the Defendant's trial based upon To the above-named Defendants: YOUAREHEREBYSUMMONEDto answer the Complaint in this action and to serve a copy of your Answer, or, is not served with this Summons,to serve a Notice of Appearance on the the Complaint if Plaintiffs' Attorneys within 20 days after the service of this Summons,exclusive of the day of service (or this Summonsis not personally within 30 days after to you within the the service is complete delivered if State of NewYork).
times hereinafter mentioned, Defendant, ELRAC,LLC Upon information and belief, at all D/B/A ENTERPRISERENT-A-CAR, was and still in the State of NewYork.
times hereinafter mentioned, Defendant, ELRAC,LLC Upon information and belief, at all D/B/A ENTERPRISERENT-A-CAR, was and still to do business in the State of NewYork.
times hereinafter mentioned, Defendant, ELRAC,LLC Upon information and belief, at all D/B/A ENTERPRISERENT-A-CAR, was and still in the State of NewYork.
falls within one or more of the exceptions contained in Article This action Plaintiff's damages exceed the jurisdictional limits of all lower courts.
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DEMAND FOR: Further Demand 3-3-25

Document CHARTAYNE DUNNING v. ELRAC, LLC D/B/A ENTERPRISE RENT-A-CAR et al, 160542/2024, 6 (N.Y. Sup. Ct., New York County Mar. 3, 2025)
PLEASE TAKE NOTICE THAT, demand is hereby made of you to serve and deliver to the Index No. 160542/2024
undersigned, within twenty (20) days from the date of service hereof, the following duly executed, properly addressed and unrestricted original, initialed HIPAA compliant authorization(s) permitting BRAND GLICK & BRAND the release of plaintiff’s records from:
PLEASE TAKE FURTHER NOTICE that pursuant to CPLR 2l03(5), the offices BRAND GLICK & BRAND, P.C., will not accept service of papers by facsimile (FAX) transmittal or other electronic means.
In the event of your failure to comply with this demand within twenty (20) days hereof this defendant will exercise its rights pursuant to the Civil Practice Law and Rules and Rules of the Appellate Division, to preclude you from offering any evidence at the trial of this action with respect to the foregoing demands.
Jeffrey E. Bondoc, Esq., duly affirms the following as true and subject to the penalties of perjury: Affirmant is not a party to the action, is over eighteen (18) years of age, is a licensed attorney in New York State and is employed by Brand, Glick & Brand, P.C. On the 3rd day of March, 2025 affirmant served the within FURTHER DEMAND FOR DISCOVERY AND INSPECTION upon:
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DEMAND FOR: Good Faith Letter Demand

Document CHARTAYNE DUNNING v. ELRAC, LLC D/B/A ENTERPRISE RENT-A-CAR et al, 160542/2024, 7 (N.Y. Sup. Ct., New York County Mar. 3, 2025)
Dear Counselor: As you are aware this office represents the defendant(s) ELRAC, LLC d/b/a ENTERPRISE RENT-A-CAR and PATRICIA WILSON in the above dated action.
On January 9, 2025, we served our Answer with various demands including one for a Bill of Particulars and a Notice for Discovery and Inspection, along with others.
In addition, we served a demand for authorizations dated January 16, 2025.
To avoid any unnecessary motion practice please be kind enough to forward your responses as soon as possible.
Should you have any questions, please feel free to contact the undersigned.
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DEMAND FOR: Further Demand 1-16-25

Document CHARTAYNE DUNNING v. ELRAC, LLC D/B/A ENTERPRISE RENT-A-CAR et al, 160542/2024, 5 (N.Y. Sup. Ct., New York County Jan. 16, 2025)
PLEASE TAKE NOTICE THAT, demand is hereby made of you to serve and deliver to the
PLEASE TAKE FURTHER NOTICE that pursuant to CPLR 2l03(5), the offices BRAND GLICK & BRAND, P.C., will not accept service of papers by facsimile (FAX) transmittal or other electronic means.
PLEASE TAKE FURTHER NOTICE, that the within demands are continuing.
In the event of your failure to comply with this demand within twenty (20) days hereof this defendant will exercise its rights pursuant to the Civil Practice Law and Rules and Rules of the Appellate Division, to preclude you from offering any evidence at the trial of this action with respect to the foregoing demands.
Jeffrey E. Bondoc, Esq., duly affirms the following as true and subject to the penalties of perjury: Affirmant is not a party to the action, is over eighteen (18) years of age, is a licensed attorney in New York State and is employed by Brand, Glick & Brand, P.C. On the 16th day of January 2025 affirmant served the within FURTHER DEMAND FOR DISCOVERY AND INSPECTION upon:
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RJI -RE: REQUEST FOR PRELIMINARY CONFERENCE

Document CHARTAYNE DUNNING v. ELRAC, LLC D/B/A ENTERPRISE RENT-A-CAR et al, 160542/2024, 4 (N.Y. Sup. Ct., New York County Jan. 9, 2025)
If none, leave blank.
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PRELIMINARY CONFERENCE REQUEST Request for PC

Document CHARTAYNE DUNNING v. ELRAC, LLC D/B/A ENTERPRISE RENT-A-CAR et al, 160542/2024, 3 (N.Y. Sup. Ct., New York County Jan. 9, 2025)
The undersigned hereby respectfully requests a Preliminary Conference in this personal injury/ motor vehicle matter in which the following attorneys have appeared:
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