On February 25, 2014 a
Motion,Ex Parte
was filed
involving a dispute between
Robin Patterson,
and
Nxk Corp. D B A Ambu-Trans Ambulette Corp.,
for Tort
in the District Court of New York County.
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FILED: NEW YORK COUNTY CLERK 08/23/2016 10:19 AM INDEX NO. 151641/2014
NYSCEF DOC. NO. 21 RECEIVED NYSCEF: 08/23/2016
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF NEW YORK
X
ROBIN PATTERSON
Plaintiff, Index No. 151641/14
-against - NOTICE OF MOTION
NXK CORP. d/b/a AMBU-TRANS AMBULETTE
CORP.
Defendant.
X
S I R S:
PLEASE TAKE NOTICE, that upon the annexed affirmation of
ERIC C. GOLDMAN, ESQ. dated August 23, 2016, and the exhibits
annexed thereto, and upon the prior pleadings and proceedings
heretofore had herein, the undersigned will move this Court at a
Motion Term of an IAS Part, Room 130 at the Courthouse located at
60 Centre Street, New York, New York, at 9:30 a.m. on the 14th
day of September, 2016, or as soon thereafter as counsel can be
heard, for an Order pursuant to CPLR §3126, striking the Answer
of Defendant NXK CORP. d/b/a AMBU-TRANS AMBULETTE CORP. for their
failure to comply with this Court's order to appear for a
deposition and respond to various discovery demands, and for such
other and further relief as this Court deems just and proper.
The above-entitled action is for personal injuries.
1 of 2
PLEASE TAKE FURTHER NOTICE, that answering affidavits, if
any, are required to be served upon the undersigned at least
seven (7) days prior to the return date of this motion.
Dated: New York, New York
August 23, 2016
Yours, etc.,
SULLIVAN PAPAIN BLOCK
McGRATH & CANNAVO P.C.
By: /
Eric C. Goldman
Attorneys for Plaintiff
120 Broadway
New York, New York 10271
(212) 732-9000
TO: Donohue Law Firm, P.C.
Attorney for Defendant
NXK CORP. d/b/a AMBU-TRANS AMBULETTE CORP.
50 Broadway, 27th Floor
New York, NY 10004
2
2 of 2
Document Filed Date
August 23, 2016
Case Filing Date
February 25, 2014
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FILED: NEW YORK COUNTY CLERK 08/23/2016 10:19 AM INDEX NO. 151641/2014 NYSCEF DOC. NO. 21 RECEIVED NYSCEF: 08/23/2016 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF NEW YORK X ROBIN PATTERSON Plaintiff, Index No. 151641/14 -against - NOTICE OF MOTION NXK CORP. d/b/a AMBU-TRANS AMBULETTE CORP. Defendant. X S I R S: PLEASE TAKE NOTICE, that upon the annexed affirmation of ERIC C. GOLDMAN, ESQ. dated August 23, 2016, and the exhibits annexed thereto, and upon the prior pleadings and proceedings heretofore had herein, the undersigned will move this Court at a Motion Term of an IAS Part, Room 130 at the Courthouse located at 60 Centre Street, New York, New York, at 9:30 a.m. on the 14th day of September, 2016, or as soon thereafter as counsel can be heard, for an Order pursuant to CPLR §3126, striking the Answer of Defendant NXK CORP. d/b/a AMBU-TRANS AMBULETTE CORP. for their failure to comply with this Court's order to appear for a deposition and respond to various discovery demands, and for such other and further relief as this Court deems just and proper. The above-entitled action is for personal injuries. 1 of 2 PLEASE TAKE FURTHER NOTICE, that answering affidavits, if any, are required to be served upon the undersigned at least seven (7) days prior to the return date of this motion. Dated: New York, New York August 23, 2016 Yours, etc., SULLIVAN PAPAIN BLOCK McGRATH & CANNAVO P.C. By: / Eric C. Goldman Attorneys for Plaintiff 120 Broadway New York, New York 10271 (212) 732-9000 TO: Donohue Law Firm, P.C. Attorney for Defendant NXK CORP. d/b/a AMBU-TRANS AMBULETTE CORP. 50 Broadway, 27th Floor New York, NY 10004 2 2 of 2