Plaintiff-respondent failed to meet her burden of establishing a meritorious cause of action by submission of an affidavit from one with personal knowledge of the underlying facts. Issue was joined in June 1985 and after no response to the demand for a bill of particulars was received, defendant-appellant served a 90-day notice in September 1987. Respondent failed to file a note of issue within the 90-day period. In opposition to appellant's motion to dismiss, respondent...
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