It is well established that a defendant may not rely on the proof submitted in its reply affidavits in order to meet its burden of proof on its motion in chief. Rengifo v City of New York, 7 AD3d 773 (2d Dept 2004); Feratovic v Lun Wah, 284 AD2d 368 (2d Dept 2001). In the oft cited case, Ritt v Lenox Hill Hosp.182 AD2d 560 (1st Dept.1992), the Court stated that:

It is well established that a defendant may not rely on the proof submitted in its reply affidavits in order to meet its burden of proof on its motion in chief. Rengifo v. City of New York, 7 AD3d 773 (2d Dept 2004) ; Feratovic v. Lun Wah, 284 A.D.2d 368 (2d Dept 2001). In the oft cited case, Ritt v. Lenox Hill Hosp. 182 A.D.2d 560 (1st Dept.1992), the Court stated that:

On summary judgment, the “bare affirmation” of an attorney, which is not based upon personal knowledge of the facts, is “without evidentiary value.” ( See Zuckerman v. City of New York, 49 N.Y.2d 557, 563, 427 N.Y.S.2d 595, 404 N.E.2d 718 [1980];Feratovic v. Lun Wah, Inc., 284 A.D.2d 368, 368–69, 725 N.Y.S.2d 892 [2d Dept.2001].) The “information and belief” of the attorney adds nothing ( see Henriquez v. Purins, 245 A.D.2d 337, 338, 666 N.Y.S.2d 190 [2d Dept.1997]; Wood v. Nourse, 124 A.D.2d 1020, 1021, 509 N.Y.S.2d 223 [4th Dept.1986] ), even when based upon the attorney's review of the client's file ( see Park Health Center v. Green Bus Lines Inc., 2002 N.Y. Slip Op 40029 [U], 2002 WL 416484 [App. Term 2nd & 11th Jud. Dists.; Building Management Co., Inc. v. Vision Quest of Flatbush, 1 Misc.3d 681] ).

This latter argument being offered by plaintiff's counsel who does not espouse any knowledge of the facts. Feratovic v. Lun Wah, Inc., 284 AD2d 368 (3rd Dept. 2001).