On July 26, 2019 a
Motion,Ex Parte
was filed
involving a dispute between
Abel Hernandez,
and
Claudio Garcia,
Quest Bam April 2016 Llc,
for Torts - Motor Vehicle
in the District Court of New York County.
Preview
FILED: NEW YORK COUNTY CLERK 11/23/2022 10:36 AM INDEX NO. 157343/2019
NYSCEF DOC. NO. 23 RECEIVED NYSCEF: 11/23/2022
SUPREME COURT FO THE STATE OF NEW YORK
COUNTY OF NEW YORK
_______________________________________________________________..x
ABEL HERNANDEZ
Plaintiff(s)
-against- Index No: 157343/2019E
AFFIRMATION
CLAUDIO GARCIA and QUEST BAM APRIL
2016 LLC,
Defendant(s)
______________________________________________________________....-x
Adam S. Ashe, Esq., an attorney admitted to practice law before the Courts of the
State of New York, affirms the following to be true, under the penalties of perjury:
1. I am a member of the firm of AMI MORGENSTERN, Attorney-at-Law
PLLC. I am the attorney for the plaintiff and as such, am fully familiar with the facts and
circumstances of the within action.
2. I submit this affirmation in compliance with Section 202.7f of the Uniform Court
Rules for the Supreme and County Courts.
3. On November 18, 2022, at the times indicated, I sent, via e-mail correspondence
to:
a) 3:18 a. .m.: AMUNDO ZWAL & SCHERMERHORN, LLP, attorneys for
defendants, at bzs@bzslaw.com said correspondence advising the Defendants, through
their counsel, that our firm would be submitted an Order to Show Cause, seeking the
Court's permission for the firm of AMI MORGENSTERN, Attorney-at-Law PLLC to
withdraw as counsel for the Plaintiff.
4. Said correspondence/email further advised the Defendants, through their counsel,
1 of 2
FILED: NEW YORK COUNTY CLERK 11/23/2022 10:36 AM INDEX NO. 157343/2019
NYSCEF DOC. NO. 23 RECEIVED NYSCEF: 11/23/2022
that the Order to Show Cause would be electronically filed on Wednesday, November
23, 2022 at 11:00am at the courthouse located at 60 Centre Street Room 315, New York,
New York 10007. Copies of the correspondence/email is annexed here to as Exhibit S.
Wherefore, your affiant has complied with proper notification pursuant to Section
202.7f on the Uniform Court Rules for the Supreme and County Courts and itis prayed
that the within Order to Show Cause, will be allowed to be presented to an Honorable
Presiding Justice, for signature and that a temporary stay will granted, so as to protect the
rights of the plaintiff.
Respectfully mitted,
ADAM S. ASHE, ESQ.,
Duly sworn to under the penalties of
18th
Perjury this day of November, 2022
2 of 2
Document Filed Date
November 23, 2022
Case Filing Date
July 26, 2019
Category
Torts - Motor Vehicle
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Preview
FILED: NEW YORK COUNTY CLERK 11/23/2022 10:36 AM INDEX NO. 157343/2019 NYSCEF DOC. NO. 23 RECEIVED NYSCEF: 11/23/2022 SUPREME COURT FO THE STATE OF NEW YORK COUNTY OF NEW YORK _______________________________________________________________..x ABEL HERNANDEZ Plaintiff(s) -against- Index No: 157343/2019E AFFIRMATION CLAUDIO GARCIA and QUEST BAM APRIL 2016 LLC, Defendant(s) ______________________________________________________________....-x Adam S. Ashe, Esq., an attorney admitted to practice law before the Courts of the State of New York, affirms the following to be true, under the penalties of perjury: 1. I am a member of the firm of AMI MORGENSTERN, Attorney-at-Law PLLC. I am the attorney for the plaintiff and as such, am fully familiar with the facts and circumstances of the within action. 2. I submit this affirmation in compliance with Section 202.7f of the Uniform Court Rules for the Supreme and County Courts. 3. On November 18, 2022, at the times indicated, I sent, via e-mail correspondence to: a) 3:18 a. .m.: AMUNDO ZWAL & SCHERMERHORN, LLP, attorneys for defendants, at bzs@bzslaw.com said correspondence advising the Defendants, through their counsel, that our firm would be submitted an Order to Show Cause, seeking the Court's permission for the firm of AMI MORGENSTERN, Attorney-at-Law PLLC to withdraw as counsel for the Plaintiff. 4. Said correspondence/email further advised the Defendants, through their counsel, 1 of 2 FILED: NEW YORK COUNTY CLERK 11/23/2022 10:36 AM INDEX NO. 157343/2019 NYSCEF DOC. NO. 23 RECEIVED NYSCEF: 11/23/2022 that the Order to Show Cause would be electronically filed on Wednesday, November 23, 2022 at 11:00am at the courthouse located at 60 Centre Street Room 315, New York, New York 10007. Copies of the correspondence/email is annexed here to as Exhibit S. Wherefore, your affiant has complied with proper notification pursuant to Section 202.7f on the Uniform Court Rules for the Supreme and County Courts and itis prayed that the within Order to Show Cause, will be allowed to be presented to an Honorable Presiding Justice, for signature and that a temporary stay will granted, so as to protect the rights of the plaintiff. Respectfully mitted, ADAM S. ASHE, ESQ., Duly sworn to under the penalties of 18th Perjury this day of November, 2022 2 of 2