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ERIC MARY-KAVANAGHT v. THE CITY OF NEW YORK et al

Docket 514763/2020, New York State, Kings County, Supreme Court (Aug. 12, 2020)
Case TypeTorts - Other (Personal Injury)
TagsTort, Civil, Other, Personal Injury
Plaintiff - Petitioner Eric Mary-kavanaght
Defendant - Respondent THE CITY OF NEW YORK
Defendant - Respondent NEW YORK CITY TRANSIT AUTHORITY
...
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ANSWER

Document ERIC MARY-KAVANAGHT v. THE CITY OF NEW YORK et al, 514763/2020, 6 (N.Y. Sup. Ct., Kings County Dec. 1, 2020)
ANSWERING DEFENDANTS deny any knowledge or information sufficient to form a belief as to allegations contained in paragraph “2” of the Verified Complaint and refer all questions of law to the court for determination.
NYCTA denies each and every allegation contained in paragraph “25” of the Verified Complaint except admits it was and still is a public benefit corporation authorized to do business in the State of New York.
ANSWERING DEFENDANTS deny each and every allegation contained in paragraph “121” of the Verified Complaint and respectfully refer all questions of law to the Court for determination.
That the liability of the answering defendant, if any, is limited to the percentage of culpability found against them by virtue of the fault of the other parties (both named and unnamed) and in accordance with the laws of the State of New York.
In the event plaintiff recovers a verdict or judgment against the answering defendant, then said verdict or judgment must be reduced pursuant to CPLR 4545(c) by those amounts which have been, or will, with reasonable certainty, replace or indemnify plaintiff, in whole or in part, for any past or future claimed economic loss, from any collateral source such as insurance, social security, workers' compensation or employee benefit programs.
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ANSWER

Document ERIC MARY-KAVANAGHT v. THE CITY OF NEW YORK et al, 514763/2020, 4 (N.Y. Sup. Ct., Kings County Oct. 9, 2020)
PLEASE TAKE NOTICE that pursuant to CPLR 3041, plaintiff(s) is required within 30 days following service of this demand to serve upon JAMES E. JOHNSON, Corporation Counsel, a verified bill of particulars setting forth in reasonable detail a statement of the following: 1.
Identify any entity by name, address and policy number to which plaintiff, or plaintiff’s spouse, domestic partner, or parent paid premiums to obtain medical or disability coverage for two years prior to the incident.
Provide duly executed authorizations (which expire upon the conclusion of this case) permitting the Office of the Corporation Counsel to obtain records pertaining to all criminal proceedings related to the incident alleged in this lawsuit.
Provide copies of any documents, records or photographs relating to any repairs made to the location, premises or item complained of in plaintiff(s) complaint prior to the happening of the alleged accident or occurrence.
Provide copies of any documents, records or logs relating to any maintenance (including cleaning, altering, and shoveling) performed at, or to, the location, premises, or item complained of in plaintiff(s) complaint prior to the happening of the alleged accident or occurrence.
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SUMMONS + COMPLAINT

Document ERIC MARY-KAVANAGHT v. THE CITY OF NEW YORK et al, 514763/2020, 1 (N.Y. Sup. Ct., Kings County Aug. 12, 2020)
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CONSENT TO CHANGE ATTORNEY (PRE RJI)

Document ERIC MARY-KAVANAGHT v. THE CITY OF NEW YORK et al, 514763/2020, 8 (N.Y. Sup. Ct., Kings County Dec. 21, 2020)
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DEMAND FOR BILL OF PARTICULARS

Document ERIC MARY-KAVANAGHT v. THE CITY OF NEW YORK et al, 514763/2020, 7 (N.Y. Sup. Ct., Kings County Dec. 1, 2020)
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AFFIRMATION/AFFIDAVIT OF SERVICE

Document ERIC MARY-KAVANAGHT v. THE CITY OF NEW YORK et al, 514763/2020, 5 (N.Y. Sup. Ct., Kings County Oct. 13, 2020)
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AFFIRMATION/AFFIDAVIT OF SERVICE

Document ERIC MARY-KAVANAGHT v. THE CITY OF NEW YORK et al, 514763/2020, 3 (N.Y. Sup. Ct., Kings County Sep. 15, 2020)
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