Motion to Amend Pleading (Add Defendant)

SUPREME COURT OF THE STATE OF NEW YORK

COUNTY OF KINGS

x Index No.: 524935/2024 ARLENE CHARLES,

Plaintiff,

NOTICE OF MOTION

-against -

NEW YORK CITY TRANSIT AUTHORITY and

METROPOLITAN TRANSPORTATION AUTHORITY

and METROPOLITAN TRANSIT AUTHORITY and

METROPOLITAN TRANSIT AUTHORITY BUS

COMPANY and MANHATTAN AND BRONX SURFACE

TRANSIT OPERATING AUTHORITY and JOHN DOE,

Defendants.

x PLEASE TAKE NOTICE that upon the affirmation of Firas E. Nesheiwat, the annexed exhibits, the pleadings, and upon all the proceedings had heretofore, the plaintiff will move this court at the Courthouse located at 360 Adams Street Brooklyn, NY 11201, on the August 7, 2026 at 9:30 a.m., or as soon thereafter as counsel can be heard, for an order amending the pleading to include defendant Hector Arroya to the action pursuant to NYCPLR §§ 3025(b) and 1003. PLEASE TAKE FURTHER NOTICE that answering affidavits, if any, must be served upon the undersigned no less than seven (7) days prior to the return date of the motion pursuant to CPLR 2214(b).

Dated: July 17, 2026

Poughkeepsie, New York

Yours, etc.

Law Office of Firas E. Nesheiwat, PC

Attorney for Plaintiff

360 Noxon Road

Poughkeepsie, NY 12603

845-***-****

TO:

Barry McTierrnan & Moore, LLC

One Battery Park Plaza, 35th Floor

New York, New York 10004

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