------------------------------------------------------------------x BORIS RAYTSIN, an attorney duly admitted to practice before the Courts of the State of New York, does hereby affirm, under penalty of perjury, as follows:
defendant driver, and as such, has not obtained testimony that, upon information and belief may serve to create triable issues of fact.
Mere conclusory statements, such as the factually unsupported use of the words “sudden” and “unexpected,” are insufficient to defeat a summary judgment motion, See Gilbert Frank Corp. v. Federal Ins. Co., 70 N.Y.2d 966, 520 N.E.2d 512 (1988).
59, Lines 14-23, attached as Exhibit “A.” Defendant's Affidavit states that he was traveling at 20 MPH, and that the impact caused his vehicle to spin counterclockwise.
------------------------------------------------------------------x BORIS RAYTSIN, an attorney duly licensed to practice before the courts of the state of New York, does hereby affirm, under penalty of perjury, as follows: