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