Your client, Leonard Dion, did not give permission and was not aware that Thomas Travoli owned a
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Question:
According to Mr. Travoli's deposition, Duke has never bitten anyone else and is, overall, a very gentle and loving dog. Plaintiffs have no evidence showing Duke bit anyone else either before or after he allegedly bit the minor plaintiff. During the depositions of the plaintiffs (parents and minor child), they testified that the minor child had played with Duke on several occasions outside in the snow and that the minor child accompanied Mr. Travoli on several walks with Duke throughout the complex prior to the alleged biting incident.
Based on this information, the attorney is going to draft a motion for summary judgment to dismiss the claim against Mr. Dion. draft an affidavit in support of the motion for the attorney's signature (Thomas Brown of Brown & Holt, P.L.L.C 1098 Parker Blvd. Williamsville, N.Y. 14221). This affidavit should outline the standard for summary judgment in general and include arguments for granting summary judgment based on NY case law for Mr. Dion's case specifically. include at least 2 NY court cases to support your argument. include a notice of motion.
For this part of the project Summons and compliant filed 2/1/2019; answer served 2/18/2019. The motion will be heard in front of Judge Jones on January 3, 2020 at the Erie County Supreme Court located at 25 Delaware Ave. Buffalo, N.Y. 14220.
To receive full credit for this assignment, you must include the following:
Proper caption format
Proper format for notice of motion and attorney affidavit
Include notice of motion and attorney affidavit
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