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ALFRED L. WHITE JR. v. SME MANAGEMENT CORP. et al

Docket 801386/2024E, New York State, Bronx County, Supreme Court (Jan. 24, 2024)
Case TypeTorts - Other (Trip and Fall)
TagsTort, Civil, Other, Slip and Fall
Plaintiff - Petitioner Alfred L. White JR.
Defendant - Respondent SME MANAGEMENT CORP.
Defendant - Respondent TACO BELL CORP.
...
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ANSWER WITH CROSS-CLAIM(S)

Document ALFRED L. WHITE JR. v. SME MANAGEMENT CORP. et al, 801386/2024E, 4 (N.Y. Sup. Ct., Bronx County May. 15, 2024)
The defendants deny knowledge or information thereof sufficient to form a belief as to the allegations contained in the paragraphs designated NINTH, TENTH, ELEVENTH, TWELFTH, THIRTEENTH, FOURTEENTH and FIFTEENTH of the verified complaint.
Duly executed and acknowledged written authorizations permitting the Defendants to obtain and copy the office records, diagnostic films and test reports of any medical or other provider who has examined the plaintiff with respect to the injuries and conditions claimed herein.
Duly executed and acknowledged written authorizations permitting the Defendants to obtain actual copies of the entire medical file and all billing records of each treating chiropractor and/or physical therapist that plaintiff has sought treatment from with respect to the injuries alleged herein.
Duly executed and acknowledged written authorizations permitting the Defendants to obtain copies of office records, diagnostic films and test reports of all medical providers who treated or examined plaintiff for prior/subsequent injuries/conditions to the same bodily parts allegedly injured herein.
Plaintiff, - against - PLEASE TAKE NOTICE, that pursuant to Article 31 of Civil Practice Law and Rules, the Defendants, TACO BELL CORPORATION AND TACO BELL OF AMERICA, LLC, will take the deposition of the plaintiff as an adverse party or parties on the 19th day of November 2024 at 10:00 A.M., before a Notary Public of the State of New York at the Law Offices of Shahab Katirachi, PENN 1, New York, NY 10119, concerning the following matters: All the relevant facts and circumstances relating to the accident including negligence, contributory negligence, liability and damages.
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SUMMONS + COMPLAINT

Document ALFRED L. WHITE JR. v. SME MANAGEMENT CORP. et al, 801386/2024E, 1 (N.Y. Sup. Ct., Bronx County Jan. 24, 2024)
its agents, servants and/or employees, undertook and agreed to own, operate, manage, supervise, monitor, control, construct, maintain and/or repair "The Premises" and the adjacent sidewalk; to keep "The Premises" and the adjacent sidewalk in good condition, reasonably safe and secure, from design structural other hazardous free defects, defects, decay, disrepair and/or and dangerous conditions.
its agents, servants or employees, disregarded their duty to properly own, operate, manage, supervise, monitor, control, construct, maintain and/or repair "The sidewalk, and carelessly, recklessly and negli!ently permitted "The Premises" Premises" and the adjacent and the adjacent dangerous condition for sidewalk to remain in an unsafe, defective, hazardous and/or a long period of time.
That the aforementioned unsafe, defective, hazardous and/or dangerous condition constituted a nuisance and that same had existed for a long period of time prior to the 29th day of May, 2022, and that the defendant,
was lawfully and properly a bicyclist and/or electric scooter operator utilizing "The Premises" and the adjacent sidewalk, the plaintiff was caused to fall with great force and violence from his electric scooter as a result of the unsafe, defective, dangerous condition of Premises" the adjacent decayed, hazardous and/or "The and sidewalk, thus sustaining the serious and severe permanent personal injuries hereinafter alleged.
care, aid and attention in an attempt to cure himself of said injuries and the plaintiff has been prevented from attending to his usual and customary daily activities.
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AFFIRMATION/AFFIDAVIT OF SERVICE

Document ALFRED L. WHITE JR. v. SME MANAGEMENT CORP. et al, 801386/2024E, 2 (N.Y. Sup. Ct., Bronx County Mar. 19, 2024)
Swom to before me on this 2nd day of February, 2024 FAITH c ZZ NOTARY PUBLic, State of New ork No. 01cO6158874, Albany county commission Expires Jan 8, 2027 Robert Guyette invoice-Work Order #2405783 Attorney File # 20849273 Form 27 - AFFIDAVIT OF SERVICE Daneris Liriano
I am over 18 years of age, not a party BASHAR JUDEH being duly sworn, deposes and says; to this action, and reside in the State of New York.
I served a true copy of the SUMMONS AND VERIFIED COMPLAINT upon ALL COUNTY, LLC the DEFENDANT therein named by delivering to, and leaving personally with TANISHA (DOE) (REFUSED FULL NAME) , RECEPTIONIST, who provided verbal confirmation that he or she is authorized to accept by appointment or law to receive service on behalf of the
I am over 18 years of age, not a NORBERTO MALDONADO being duly sworn, deposes and says; party to this action, and reside in the State of New York.
I am over 18 years of age, not a ROBERT BONNET being duly affirmed, deposes and says; party to this action, and reside in the State of New York.
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AFFIRMATION/AFFIDAVIT OF SERVICE

Document ALFRED L. WHITE JR. v. SME MANAGEMENT CORP. et al, 801386/2024E, 3 (N.Y. Sup. Ct., Bronx County Mar. 19, 2024)
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