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NIA ROLLINS v. JPMORGAN CHASE & CO. et al

Docket 702979/2024, New York State, Queens County, Supreme Court
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21

Document NIA ROLLINS v. JPMORGAN CHASE & CO. et al, 702979/2024, 21 (N.Y. Sup. Ct., Queens County May. 23, 2024)
(6) Other Disclosure: (a) Within ninety (90) days from the date hereof,all parties shall exchange names and addresses of all witnesses, and shall exchange statementsof opposing parties and photographs, or,if none, shall provide an ...
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35

Document NIA ROLLINS v. JPMORGAN CHASE & CO. et al, 702979/2024, 35 (N.Y. Sup. Ct., Queens County Jun. 21, 2024)
Re: Nia Rollins v. JPMorgan Chase & Co., 156-33 Cross Bay Boulevard LLC, Jones Lang LaSalle Americas Inc., Brightview Enterprise Solutions LLC, and JCS Maintenance Corp.
Nia Rollins Queens County JCS Maintenance Corp. 604720/2023 Kaufman Dolowich LLP is counsel for defendant JCS MAINTENANCE CORP. in the captioned lawsuit.
Please allow the following to serve as defendants’ demand for a copy of the pleadings, discovery demands, discovery responses for the other action commenced by the plaintiff for the same date of loss styled as Nia Rollins v. JPMorgan Chase & Co. and 156-33 Cross Bay Boulevard LLC under Index No.: 704883/2022.
Please provide responses within 21 days to avoid unnecessary judicial intervention.
Note our continuing demands for updated Special Damages and supporting documentation, lien information and supporting documentation, photographs, witness information.
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23

Document NIA ROLLINS v. JPMORGAN CHASE & CO. et al, 702979/2024, 23 (N.Y. Sup. Ct., Queens County May. 29, 2024)
JONES LANGLASALLE AMERICAS, INC., by their The defendant, SOBELPEVZNER,LLC, answering the Complaint of the plaintiff, alleges upon information attorneys, and belief:
in paragraphs Defendant denies, upon information "8" through "19", all inclusive, and belief, each and every allegation contained of the Complaint, and respectfully refers all questions of law to this Honorable Court.
That upon information and belief, the damages claimed were caused or contributed to by subsequent and/or intervening acts of negligence by parties other than the answering defendant.
Upon information and belief, the property which is the subject matter of this lawsuit has been destroyed, removed, altered or in other ways changed such that spoliation of evidence in whole or in part.
stated upon my own knowledge are as is that principal place of business is in a County other The grounds of my belief as to all matters not follows: Contents of file, which constitutes attorney's work product.
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14

Document NIA ROLLINS v. JPMORGAN CHASE & CO. et al, 702979/2024, 14 (N.Y. Sup. Ct., Queens County May. 15, 2024)
Defendant denies knowledge or information sufficient to form a belief as to the truth of the allegations contained in paragraphs “1”, “2”, “3”, “4” and “5” of the Complaint.
The amount of alleged damages claimed by Plaintiff shall be reduced pursuant to §4545 of New York’s Civil Practice Law and Rules to the extent of any collateral source benefits, remuneration or compensation received.
If Plaintiff was caused to sustain injuries or damages as alleged in the Complaint, said injuries and damages were sustained by reason of the negligence, carelessness and/or recklessness on the part of the Co-Defendants and their respective employees, principals, agents, etc., without any negligence, carelessness or recklessness on the part of this Answering Defendant.
Accordingly, this Answering Defendant will be entitled to full and complete indemnity from said Co-Defendants and their respective employees, principals, agents, etc., for all losses and damages sustained, together with costs, disbursements and reasonable attorney’s fees.
WHEREFORE, Defendant JCS MAINTENANCE CORP. demands judgment dismissing the Complaint of the Plaintiff herein, together with costs, attorney’s fees and disbursements of this action, as well as such other and further relief as this Court deems just, equitable and proper.
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7

Document NIA ROLLINS v. JPMORGAN CHASE & CO. et al, 702979/2024, 7 (N.Y. Sup. Ct., Queens County Apr. 30, 2024)

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9

Document NIA ROLLINS v. JPMORGAN CHASE & CO. et al, 702979/2024, 9 (N.Y. Sup. Ct., Queens County Apr. 30, 2024)
If none, leave blank.
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4

Document NIA ROLLINS v. JPMORGAN CHASE & CO. et al, 702979/2024, 4 (N.Y. Sup. Ct., Queens County Apr. 30, 2024)
Affirmation of GREGORY E. BROWER, dated April 30, 2024, Affirmation of Good Faith, dated April 30, 2024, and supporting exhibits.
An Order pursuant to CPLR §3211(a)(8) in that the Court does not have jurisdiction of the person of the defendant, BRIGHTVIEW ENTERPRISE SOLUTIONS LLC, in that the Summons and Complaint was not properly served; or alternatively, dismissing the action under CPLR §214 in that the action was not timely commenced; together with such other and further relief as to this Court may deem just and proper.
PLEASE TAKE FURTHER NOTICE, that pursuant to CPLR §2214(b), all answering affidavits, if any, are required to be served at least seven (7) days prior to the return date of this motion.
Attorneys for Plaintiff Office & P.O.
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