On February 25, 2014 a
Motion,Ex Parte
was filed
involving a dispute between
Alberto Collado,
and
Ermogeno Peralta,
Miguel A. Rodriguez-Acevedo,
for Tort
in the District Court of New York County.
Preview
(FILED: NEW YORK COUNTY CLERK 06/10/2015 04:39 PM INDEX NO. 151648/2014
NYSCEF DOC. NO. 22 RECEIVED NYSCEF: 06/24/2015
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF NEW YORK
ewecuesusoses: cars “XX
ALBERTO COLLADO,
Index No.: 151648/14
NOTICE OF MOTION
Plaintiff, FOR SUMMARY
JUDGMENT ON
LIABILITY
-against-
ERMOGENO PERALTA and
MIGUEL A. RODRIGUEZ-ACEVADO, Assigned Justice:
Hon. Arlene P. Bluth
Defendant. Returnable:
ee eew en nennnnneweneen
meen ne nennnnnenneneeenenee. “-X July 20, 2015
PLEASE TAKE NOTICE that upon the annexed Affirmation of HARLAN
WITTENSTEIN, duly affirmed this 9th day of June, 2015, the affidavit of Alberto
Collado duly sworn on the 9" day of June, 2015, the affidavit of Daisy Perez duly
sworn on the 9" day of June, 2015, and upon all the pleadings and proceedings
heretofore had herein, the undersigned will move this Court before the Motion
Submission Part at the Supreme Court, New York County located at 60 Centre Street,
aj=
Room 130, New York, New York, on the 20" day of July, 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 CPLR §3212 granting plaintiff ALBERTO COLLADO summary judgment against
the defendants on the issue of liability together with such other and further relief as to
this Court may seem just and proper.
PLEASE TAKE FURTHER NOTICE that answering affidavits, if any, are to be
served so as to be received no less than seven days prior to the return date herein
pursuant to CPLR 2214(b).
Dated: Brooklyn, New York
June 19, 2015
Yours, etc.,
TARASOV & ASSOCIATES, P.C.
ByZ
Cc
HARLAN WITTENSTEIN
Tarasov & Associates, P.C.
Attorneys for Plaintiff
2566 86" Street
Brooklyn, New York 11214
(718) 265-0022
TO: BAKER, McEVOY, MORRISSEY & MOSKOVITS, P.C.
Attorneys for Defendants
1 Metrotech Center
Brooklyn, New York 11201
(212) 857-8230
~2-
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF NEW YORK Index No.: 151648/2014
ALBERTO COLLADO,
Plaintiff,
- against -
ERMOGENO, PERALTA and MIGUEL, A
RODRIGUEZ-ACEVEDO,
Defendants.
NOTICE OF MOTION FOR SUMMARY JUDGMENT ON LIABILITY;
AFFIRMATION IN SUPPORT
TARASOV & ASSOCIATES, P.C.
Attorneys for Plaintiff ALBERTO COLLADO
Office and Post Office Address, Telephone
2566 86" Street, Suite 2
Brooklyn, NY 11214
718-265-0022
Service of a copy of the within
is hereby admitted.
Dated: 20.
Signature (ule 130-11.1-a)
PRINT NAME BENE. ATH
Attorney(s)
for
PLEASE TAKE NOTICE:
° JOTICE OF ENTR’
that the within is a (certified) true copy of a
Duly entered in the office of the clerk of the within named court on 20
° NOTICE
OF SETTLEMENT
that an order of which the within is a true copy
will be presented for settlement to the HON. One of the judges of the
within named Court, at
on 20 at M.
Dated, Yours, etc.
Document Filed Date
June 24, 2015
Case Filing Date
February 25, 2014
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(FILED: NEW YORK COUNTY CLERK 06/10/2015 04:39 PM INDEX NO. 151648/2014 NYSCEF DOC. NO. 22 RECEIVED NYSCEF: 06/24/2015 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF NEW YORK ewecuesusoses: cars “XX ALBERTO COLLADO, Index No.: 151648/14 NOTICE OF MOTION Plaintiff, FOR SUMMARY JUDGMENT ON LIABILITY -against- ERMOGENO PERALTA and MIGUEL A. RODRIGUEZ-ACEVADO, Assigned Justice: Hon. Arlene P. Bluth Defendant. Returnable: ee eew en nennnnneweneen meen ne nennnnnenneneeenenee. “-X July 20, 2015 PLEASE TAKE NOTICE that upon the annexed Affirmation of HARLAN WITTENSTEIN, duly affirmed this 9th day of June, 2015, the affidavit of Alberto Collado duly sworn on the 9" day of June, 2015, the affidavit of Daisy Perez duly sworn on the 9" day of June, 2015, and upon all the pleadings and proceedings heretofore had herein, the undersigned will move this Court before the Motion Submission Part at the Supreme Court, New York County located at 60 Centre Street, aj= Room 130, New York, New York, on the 20" day of July, 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 CPLR §3212 granting plaintiff ALBERTO COLLADO summary judgment against the defendants on the issue of liability together with such other and further relief as to this Court may seem just and proper. PLEASE TAKE FURTHER NOTICE that answering affidavits, if any, are to be served so as to be received no less than seven days prior to the return date herein pursuant to CPLR 2214(b). Dated: Brooklyn, New York June 19, 2015 Yours, etc., TARASOV & ASSOCIATES, P.C. ByZ Cc HARLAN WITTENSTEIN Tarasov & Associates, P.C. Attorneys for Plaintiff 2566 86" Street Brooklyn, New York 11214 (718) 265-0022 TO: BAKER, McEVOY, MORRISSEY & MOSKOVITS, P.C. Attorneys for Defendants 1 Metrotech Center Brooklyn, New York 11201 (212) 857-8230 ~2- SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF NEW YORK Index No.: 151648/2014 ALBERTO COLLADO, Plaintiff, - against - ERMOGENO, PERALTA and MIGUEL, A RODRIGUEZ-ACEVEDO, Defendants. NOTICE OF MOTION FOR SUMMARY JUDGMENT ON LIABILITY; AFFIRMATION IN SUPPORT TARASOV & ASSOCIATES, P.C. Attorneys for Plaintiff ALBERTO COLLADO Office and Post Office Address, Telephone 2566 86" Street, Suite 2 Brooklyn, NY 11214 718-265-0022 Service of a copy of the within is hereby admitted. Dated: 20. Signature (ule 130-11.1-a) PRINT NAME BENE. ATH Attorney(s) for PLEASE TAKE NOTICE: ° JOTICE OF ENTR’ that the within is a (certified) true copy of a Duly entered in the office of the clerk of the within named court on 20 ° NOTICE OF SETTLEMENT that an order of which the within is a true copy will be presented for settlement to the HON. One of the judges of the within named Court, at on 20 at M. Dated, Yours, etc.