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MARIE A EXORPHE v. JOON H KIM et al

Docket 710055/2021, New York State, Queens County, Supreme Court (May 3, 2021)
Case TypeTorts - Motor Vehicle
TagsTort, Civil, Vehicle
Plaintiff - Petitioner Marie A Exorphe
Defendant - Respondent Joon H Kim
Defendant - Respondent KOREAN CHURCH OF QUEENS
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STIPULATION - DISCOVERY ( REQUEST TO SO ORDER )

Document MARIE A EXORPHE v. JOON H KIM et al, 710055/2021, 29 (N.Y. Sup. Ct., Queens County Jul. 27, 2021)
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EXHIBIT(S)

Document MARIE A EXORPHE v. JOON H KIM et al, 710055/2021, 16 (N.Y. Sup. Ct., Queens County May. 28, 2021)
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EXHIBIT(S)

Document MARIE A EXORPHE v. JOON H KIM et al, 710055/2021, 17 (N.Y. Sup. Ct., Queens County May. 28, 2021)
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EXHIBIT(S)

Document MARIE A EXORPHE v. JOON H KIM et al, 710055/2021, 15 (N.Y. Sup. Ct., Queens County May. 28, 2021)
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EXHIBIT(S)

Document MARIE A EXORPHE v. JOON H KIM et al, 710055/2021, 13 (N.Y. Sup. Ct., Queens County May. 28, 2021)
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AFFIDAVIT OR AFFIRMATION IN SUPPORT OF MOTION

Document MARIE A EXORPHE v. JOON H KIM et al, 710055/2021, 7 (N.Y. Sup. Ct., Queens County May. 28, 2021)
David A. Bonilla, Esq., an attorney duly admitted to practice law before the Courts of the State of New York, affirms the following under the penalties of perjury:
As a result of the aforementioned incident, Plaintiff commenced an instant action in the Supreme Court of the New York, County of Queens, by filing and serving a Summons and Verified Complaint, dated February 21, 2013.
Plaintiff filed her Note of Issue on September 29, 2014, pursuant to the Compliance Conference Order dated June 25, 2014, stating that case is not ready for trial and discovery remains outstanding.
The parties appeared On March 22, 2018, for a pretrial conference, at which time the Note of Issue was vacated due to outstanding discovery, which included a further EBT of the Plaintiff.
On September 21, 2020 your affirmant's office attempted to resolve the discovery issue outlined herein by contacting defense counsel, Ms. Shelly Werbel via telephone.
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EXHIBIT(S)

Document MARIE A EXORPHE v. JOON H KIM et al, 710055/2021, 18 (N.Y. Sup. Ct., Queens County May. 28, 2021)
that the within is a true copy of an Order dated August 2017, and duly entered in the office of the clerk of the within wamcd court on or about the 24, 4* day of September, 2018.
(Sowerby contumaciousness with the offered 3126, Camarda, court's to Willfulness to failures comply explanation of (id.).
for that one and it the hundred is extended discovery; time to twenty file (120) summary days judgment following motions completion further
Janet Bergollo, being duly sworn, deposes and says: I am not a party to the within action, am over 18 years of age and reside in Queens, New That York.
same of February, upon the in a mailbox served deponent 2020 listed attorneys and parties of New York: in the State the below within by United
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