Preview
INDEX NO. 151998/2014
(FILED: NEW YORK COUNTY CLERK 0372372017 03:54 PM
NYSCEF DOC. NO. 64 RECEIVED NYSCEF: 03/23/2017
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF NEW YORK
wooX
THORA CLAUDETTE CHALLENGER, Index No.: 151998/14
Plaintiff,
-against- NOTICE OF MOTION
GEORGE J. LAMADELEINE, J.B. HUNT
TRANSPORT, INC., ZEPHANIAH P. MULLIN, and
CHARLES S. GILES,
Defendants.
Seeiieseneeneauaaeiere
NESE ee aul
COUNSELORS:
PLEASE TAKE NOTICE, that upon the annexed Affirmation of Iolanda V. D’Ambrosi-
Francavilla, Esq., sworn to on the 23rd day of March, 2017, the exhibits annexed thereto, and
upon all pleadings and proceedings heretofore had herein, defendants, GEORGE J.
LAMADELEINE and J.B. HUNT TRANSPORT, INC., (“Defendants”), by and through their
attorneys, RAWLE & HENDERSON LLP, shall move this Court at Room 130 of the New York
County Supreme Court, 60 Centre Street, New York, New York 10007, on the 13" day of April,
2017, at 9:30 o’clock in the forenoon of that day, or as soon thereafter as counsel may be heard,
for an Order:
Pursuant to 22 NYCRR §202.21, vacating the Note of Issue and Certificate of
Readiness and striking this action from the trial calendar, on the ground that all pre-
trial discovery is not complete and this matter is not ready for trial;
Pursuant to CPLR §3124, compelling plaintiff to provide all outstanding discovery
outlined herein, by a date certain;
Extending defendants’ time to move for Summary Judgment; and
For such other and further relief in favor of defendants as this Court deems just and
proper.
10280337-1
1 of 2
INDEX NO. 151998/2014
(FILED: NEW YORK COUNTY CLERK 0372372017 03:54 PM
NYSCEF DOC. NO. 64 RECEIVED NYSCEF: 03/23/2017
PLEASE TAKE FURTHER NOTICE, that sufficient notice having been given to you,
answering papers, if any, must be received by this office no later than seven (7) days prior to the
return date of this motion, pursuant to CPLR §2214(b).
Dated: New York, New York
March 23, 2017
Yours, etc.
RAWLE & HENDERSON LLP
)
| a spall,
Tolanda V. D’Ambrosi-Francavilla
Attorneys for Defendants
GEORGE J. LAMADELEINE
and J.B. HUNT TRANSPORT,
INC.
14 Wall Street -27" Floor
New York, New York 10005-2101
Telephone No.: 1 (212) 323-7070
Our File No.: 803330
TO WILLIAM SCHWITZER & ASSOCIATES, P.C.
Attorneys for Plaintiff
820 Second Avenue- 10" Floor
New York, New York 10013
Telephone No.: 1 (212) 683-3800
THE NOLL LAW FIRM, P.C.
Attorneys for Defendants
ZEPHANIAH P. MULLIN and
CHARLES S. GILES
33 Queens Street, Suite 102
Syosset, New York 11791
Telephone No.: 1 (516) 307-1199
10280337-1
2 of 2
Preview
INDEX NO. 151998/2014 (FILED: NEW YORK COUNTY CLERK 0372372017 03:54 PM NYSCEF DOC. NO. 64 RECEIVED NYSCEF: 03/23/2017 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF NEW YORK wooX THORA CLAUDETTE CHALLENGER, Index No.: 151998/14 Plaintiff, -against- NOTICE OF MOTION GEORGE J. LAMADELEINE, J.B. HUNT TRANSPORT, INC., ZEPHANIAH P. MULLIN, and CHARLES S. GILES, Defendants. Seeiieseneeneauaaeiere NESE ee aul COUNSELORS: PLEASE TAKE NOTICE, that upon the annexed Affirmation of Iolanda V. D’Ambrosi- Francavilla, Esq., sworn to on the 23rd day of March, 2017, the exhibits annexed thereto, and upon all pleadings and proceedings heretofore had herein, defendants, GEORGE J. LAMADELEINE and J.B. HUNT TRANSPORT, INC., (“Defendants”), by and through their attorneys, RAWLE & HENDERSON LLP, shall move this Court at Room 130 of the New York County Supreme Court, 60 Centre Street, New York, New York 10007, on the 13" day of April, 2017, at 9:30 o’clock in the forenoon of that day, or as soon thereafter as counsel may be heard, for an Order: Pursuant to 22 NYCRR §202.21, vacating the Note of Issue and Certificate of Readiness and striking this action from the trial calendar, on the ground that all pre- trial discovery is not complete and this matter is not ready for trial; Pursuant to CPLR §3124, compelling plaintiff to provide all outstanding discovery outlined herein, by a date certain; Extending defendants’ time to move for Summary Judgment; and For such other and further relief in favor of defendants as this Court deems just and proper. 10280337-1 1 of 2 INDEX NO. 151998/2014 (FILED: NEW YORK COUNTY CLERK 0372372017 03:54 PM NYSCEF DOC. NO. 64 RECEIVED NYSCEF: 03/23/2017 PLEASE TAKE FURTHER NOTICE, that sufficient notice having been given to you, answering papers, if any, must be received by this office no later than seven (7) days prior to the return date of this motion, pursuant to CPLR §2214(b). Dated: New York, New York March 23, 2017 Yours, etc. RAWLE & HENDERSON LLP ) | a spall, Tolanda V. D’Ambrosi-Francavilla Attorneys for Defendants GEORGE J. LAMADELEINE and J.B. HUNT TRANSPORT, INC. 14 Wall Street -27" Floor New York, New York 10005-2101 Telephone No.: 1 (212) 323-7070 Our File No.: 803330 TO WILLIAM SCHWITZER & ASSOCIATES, P.C. Attorneys for Plaintiff 820 Second Avenue- 10" Floor New York, New York 10013 Telephone No.: 1 (212) 683-3800 THE NOLL LAW FIRM, P.C. Attorneys for Defendants ZEPHANIAH P. MULLIN and CHARLES S. GILES 33 Queens Street, Suite 102 Syosset, New York 11791 Telephone No.: 1 (516) 307-1199 10280337-1 2 of 2