On February 25, 2014 a
Motion,Ex Parte
was filed
involving a dispute between
Marie-Jose Bernard,
and
Claire Zaglauer,
Elizabeth Cros,
New York French American Charter School,
for Commercial (General)
in the District Court of New York County.
Preview
(FILED: NEW YORK COUNTY CLERK 0671672014 05:37 PM INDEX NO. 650621/2014
NYSCEF DOC. NO. 6 RECEIVED NYSCEF 06/17/2014
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF NEW YORK
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MARIE-JOSE BERNARD,
Plaintiff, Index No.: 650621/2014
vs.
NEW YORK FRENCH AMERICAN CHARTER NOTICE OF MOTION
SCHOOL, CLAIRE ZAGLAUER and ELIZABETH
CROS.,
Defendants.
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PLEASE TAKE NOTICE, that upon the annexed Affirmation of Sarir Z. Silver, Esq.,
dated the 13" day of June, 2014 and all of the exhibits annexed hereto, the undersigned will
move this Court at the Courthouse located at 60 Centre Street, New York, New York 10007 in
the Submission Part, Room 130 on the Ist day of August, 2014, at 9:30 o’clock in the forenoon
of that day, or as soon thereafter as counsel can be heard, for an Order pursuant to Civil Practice
Law and Rules § 321 1(a)(7) and (a)(1) dismissing the Second Amended Complaint in its entirety
against Defendants New York French American Charter School and Elisabeth Cros, improperly
pled as Elizabeth Cros (together “Defendants”); CPLR § 3214(b) staying discovery pending
disposition of the within motion; and, for such other and further relief as this Court deems just,
proper and equitable.
Pursuant to CPLR § 2214(b), answering papers, if any, are to be served upon the
undersigned at least seven (7) days prior to the return date hereof.
Dated: New York, New York
June 13, 2014
Respectfully Submitted,
GORDON & REES, LLP
By:
Sarir Z. Silver
Benjamin A. Levine
90 Broad Street, 23rd Floor
New York, New York 10004
(212) 269-5500
silver@gordonrees.com
blevine@gordonrees.com
To J. Patrick DeLince, Esq.
DELINCE LAW PLLC
Attorneys for Plaintiff
30 Broad Street, 14" Floor
New York, New York 10004
(212) 382-3544
1095919/19851822v.1
Document Filed Date
June 17, 2014
Case Filing Date
February 25, 2014
Category
Commercial (General)
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