Affirmation in Support of Motion to Amend Complaint and Bill of Particulars

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____________, an attorney duly licensed to practice law before the Courts of the State of New York, under the penalty of perjury affirms as follows:

1. I am associated with the firm of ________________________, attorneys for the plaintiff, and as such am familiar with the pleadings and proceedings heretofore had herein and submit this Affirmation in support of the within Motion.

2. I submit this Affirmation in support of the within application to increase the ad damnum clause of the Complaint, and the Bill of Particulars on the grounds that the present ad damnum clause is insufficient to fairly and adequately compensate the plaintiff for the injuries sustained herein (Copies are annexed as Exhibits “1” and “2”).

3. This is an action for personal injuries sustained on _________, ____ at approximately _:__ p.m. in front of the MACY’S at 34th Street and Seventh Avenue, New York, New York. At the time of the incident, the...