Affirmation in Support of Motion to Add Defendants and Amend Caption

[Caption]

__________ [Name], Esq., an attorney duly admitted to practice law before the Courts of the State of New York, affirms the following to be true under the penalties of perjury.

  1. I am the attorney for the Plaintiffs and as such am fully familiar with all the facts and circumstances surrounding this matter and with all of the prior proceedings.

  2. I submit this Affirmation to respectfully request that, pursuant to CPLR 3025(b), this Court grant Plaintiffs leave to amend the above caption of Plaintiffs' instant Complaint to include two additional Defendants.

  3. The instant action was originally commenced by service of a Summons and Verified Complaint upon Defendants on __________ [Date]. Annexed hereto as Exhibit "__" and made a part hereof is a copy of that complaint.

  4. The Defendants served Plaintiffs with a Verified Answer on __________ [Date]. Annexed hereto as Exhibit "

    __" and made a part hereof is a copy of that answer.

  5. Plaintiffs commenced this action to recover for personal injuries sustained by Plaintiff __________ [Name] as a result of a slip and fall accident on the sidewalk maintained and controlled by the Defendants and the subsequent loss of consortium suffered by Plaintiff __________ [Name].

  6. Your Affirmant recently became aware that additional Defendants are necessary parties to the above-captioned action.

  7. ...

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