On February 25, 2014 a
Motion,Ex Parte
was filed
involving a dispute between
Mark Karten,
Shelley Karten,
and
500-512 Seventh Avenue Lp, Llc.,,
Consolidated Edison Company Of New York, Inc.,
G&E Real Estate Management Services, Inc,
Gibraltar Contracting, Inc,
Newmark Grubb Knight Frank,
for Tort
in the District Court of New York County.
Preview
(FILED: NEW YORK COUNTY CLERK 0472872017 03:09 PM INDEX NO. 151650/2014
NYSCEF DOC. NO. 41 RECEIVED NYSCEF: 04/28/2017
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF NEW YORK
wenn e ete n een nee n eee rene ene een en nnn nee ne,
SHELLEY KARTEN and MARK KARTEN,
Index No.: 151650/14
Plaintiffs,
NOTICE OF MOTION
-against-
500-512 SEVENTH AVENUE LP, LLC.,
NEWMARK GRUBB KNIGHT FRANK and
NEW YORK, INC., GIBRALTAR
CONTRACTING INC. and G&E REAL ESTATE
MANAGEMENT SERVICES, INC.
Defendants.
watt nnn nnn ne
enn eee eee ee
CONSOLIDATED EDISON COMPANY OF NEW YORK.
>
INC.,
Index No. 595637/2015
Third Party Plaintiff,
-against-
NAMOW, INC.,
Third Party Defendant.
wanna
enn n nnn ee eens
PLEASE TAKE NOTICE, that upon the attached affirmation of JAMES
W. BACHER,
ESQ., dated April 28, 2017, and upon all the papers and proceedings had
herein, a Motion will
be made before the Motion Support Office, Room 130, Supreme Court, New
York County
located at 60 Centre Street, New York, NY on the 26" of May, 2017,
at 9:30 o’clock in the
forenoon of that day, or as soon thereafter as counsel can be heard for an
order striking the
Answer of the defendant 500-512 SEVENTH AVENUE LP, LLC and
other defendants who
have failed to conduct discovery and comply with the prior court orders of this
court, or in the
alternative, compelling the defendant to provide such discovery pursuan
t to court orders and
demands previously filed herewith, and for such other and further relief as
this court may deem
1 of 2
(FILED: NEW YORK COUNTY CLERK 0472872017 03:09 PM INDEX NO. 151650/2014
NYSCEF DOC. NO. 41 RECEIVED NYSCEF: 04/28/2017
just and proper.
PLEASE TAKE FURTHER NOTICE that answering affidavits, if any, are
required to be served at least seven (7) days prior to the return date of this motion.
Dated: New York, New York Yours, etc.
April 28, 2017
SAFTLER & BACHER, PLLC
Attoi ‘ys for Plajntiff
BY:
s W. Bacher, Esq.
Madison Avenue, Ste. 1605
New York, New York 10016
TO: 646.865.0797 (0)
646.865.0801 (f)
Crisci Weiser & McCarthy
Attorney for Defendant
500-521 SEVENTH AVENUE LP and
NEWMARK GRUBB KNIGHT FRANK
17 State St., 8 Floor
New York, NY 10004
(212) 943-8940
File No.: 15-290419-SLR
Bonner Kiernan Trebach
& Crociata, LLP
Attorneys for Defendant
G&E REAL ESTATE MANAGEMENT, INC.
Empire State Building, 59" Fl.
350 Fifth Avenue
New York, NY 10118
David M. Santoro
Attorney for Defendant and Third Part Plaintiff
CONSOLIDATED EDISON COMPANY
OF NEW YORK, INC.
4 Irving Place, Ste. 1800
New York, New York 10003
Gialleonardo Mcdonald & Turchetti, Esqs.
Attorneys for Third Party Defendant
NAMOW, INC.
One Whitehall Street
New York, NY 10004-2109
Matter No.: 15-022560
2 of 2
Preview
(FILED: NEW YORK COUNTY CLERK 0472872017 03:09 PM INDEX NO. 151650/2014 NYSCEF DOC. NO. 41 RECEIVED NYSCEF: 04/28/2017 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF NEW YORK wenn e ete n een nee n eee rene ene een en nnn nee ne, SHELLEY KARTEN and MARK KARTEN, Index No.: 151650/14 Plaintiffs, NOTICE OF MOTION -against- 500-512 SEVENTH AVENUE LP, LLC., NEWMARK GRUBB KNIGHT FRANK and NEW YORK, INC., GIBRALTAR CONTRACTING INC. and G&E REAL ESTATE MANAGEMENT SERVICES, INC. Defendants. watt nnn nnn ne enn eee eee ee CONSOLIDATED EDISON COMPANY OF NEW YORK. > INC., Index No. 595637/2015 Third Party Plaintiff, -against- NAMOW, INC., Third Party Defendant. wanna enn n nnn ee eens PLEASE TAKE NOTICE, that upon the attached affirmation of JAMES W. BACHER, ESQ., dated April 28, 2017, and upon all the papers and proceedings had herein, a Motion will be made before the Motion Support Office, Room 130, Supreme Court, New York County located at 60 Centre Street, New York, NY on the 26" of May, 2017, at 9:30 o’clock in the forenoon of that day, or as soon thereafter as counsel can be heard for an order striking the Answer of the defendant 500-512 SEVENTH AVENUE LP, LLC and other defendants who have failed to conduct discovery and comply with the prior court orders of this court, or in the alternative, compelling the defendant to provide such discovery pursuan t to court orders and demands previously filed herewith, and for such other and further relief as this court may deem 1 of 2 (FILED: NEW YORK COUNTY CLERK 0472872017 03:09 PM INDEX NO. 151650/2014 NYSCEF DOC. NO. 41 RECEIVED NYSCEF: 04/28/2017 just and proper. PLEASE TAKE FURTHER NOTICE that answering affidavits, if any, are required to be served at least seven (7) days prior to the return date of this motion. Dated: New York, New York Yours, etc. April 28, 2017 SAFTLER & BACHER, PLLC Attoi ‘ys for Plajntiff BY: s W. Bacher, Esq. Madison Avenue, Ste. 1605 New York, New York 10016 TO: 646.865.0797 (0) 646.865.0801 (f) Crisci Weiser & McCarthy Attorney for Defendant 500-521 SEVENTH AVENUE LP and NEWMARK GRUBB KNIGHT FRANK 17 State St., 8 Floor New York, NY 10004 (212) 943-8940 File No.: 15-290419-SLR Bonner Kiernan Trebach & Crociata, LLP Attorneys for Defendant G&E REAL ESTATE MANAGEMENT, INC. Empire State Building, 59" Fl. 350 Fifth Avenue New York, NY 10118 David M. Santoro Attorney for Defendant and Third Part Plaintiff CONSOLIDATED EDISON COMPANY OF NEW YORK, INC. 4 Irving Place, Ste. 1800 New York, New York 10003 Gialleonardo Mcdonald & Turchetti, Esqs. Attorneys for Third Party Defendant NAMOW, INC. One Whitehall Street New York, NY 10004-2109 Matter No.: 15-022560 2 of 2