On February 13, 2014 a
Motion,Ex Parte
was filed
involving a dispute between
Juan Ramirez,
and
Nelson Santiago,
for Tort
in the District Court of New York County.
Preview
FILED: NEW YORK COUNTY CLERK 07/09/2015 10:28 AM INDEX NO. 151317/2014
NYSCEF DOC. NO. 19 RECEIVED NYSCEF: 07/09/2015
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF NEW YORK
----------------------------------------------------------------------------X Index No.: 15131712014
JUAN RAMIREZ,
Plaintiffs, NOTICE OF MOTION
-against-
NELSON SANTIAGO
Defendants.
----------------------------------------------------------------------------X
PLEASE TAKE NOTICE that, upon the affirmation of Philip S. Abate, Esq.,
dated July 8, 2015 and upon the annexed exhibits, the plaintiffs will move this Court before Motion
Support Office, located at 60 Centre Street, New York, NY 10007, in the Motion Support Part,
Room 130, August 10, 2015 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 CPLR §3124 and §3126, striking the defendant,
NELSON SANTIAGO's Answer or precluding them from offering testimony at trial, together
with such other and further relief as this Court may deem just and proper.
PLEASE TAKE FURTHER NOTICE that, pursuant to CPLR §2214(b), answering
affidavits, if any, are to be served upon the undersigned no later than seven (7) days prior to the
return date hereof.
Dated: New York, New York
July 8, 2015
PHILIPS. ABATE, ESQ., P.C.
By:
Id~
Philip S. Abate
Attorney for Plaintiff
111 John Street, Suite 1005
New York, NY 10038
(212) 267-3738
TO: KAY &GRAY
Attorneys for Defendant,
NELSON SANTIAGO
875 Merrick Avenue
Westbury, NY 11590
Tel: (516) 229-4427
File No.: 14R0575
Document Filed Date
July 09, 2015
Case Filing Date
February 13, 2014
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FILED: NEW YORK COUNTY CLERK 07/09/2015 10:28 AM INDEX NO. 151317/2014 NYSCEF DOC. NO. 19 RECEIVED NYSCEF: 07/09/2015 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF NEW YORK ----------------------------------------------------------------------------X Index No.: 15131712014 JUAN RAMIREZ, Plaintiffs, NOTICE OF MOTION -against- NELSON SANTIAGO Defendants. ----------------------------------------------------------------------------X PLEASE TAKE NOTICE that, upon the affirmation of Philip S. Abate, Esq., dated July 8, 2015 and upon the annexed exhibits, the plaintiffs will move this Court before Motion Support Office, located at 60 Centre Street, New York, NY 10007, in the Motion Support Part, Room 130, August 10, 2015 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 CPLR §3124 and §3126, striking the defendant, NELSON SANTIAGO's Answer or precluding them from offering testimony at trial, together with such other and further relief as this Court may deem just and proper. PLEASE TAKE FURTHER NOTICE that, pursuant to CPLR §2214(b), answering affidavits, if any, are to be served upon the undersigned no later than seven (7) days prior to the return date hereof. Dated: New York, New York July 8, 2015 PHILIPS. ABATE, ESQ., P.C. By: Id~ Philip S. Abate Attorney for Plaintiff 111 John Street, Suite 1005 New York, NY 10038 (212) 267-3738 TO: KAY &GRAY Attorneys for Defendant, NELSON SANTIAGO 875 Merrick Avenue Westbury, NY 11590 Tel: (516) 229-4427 File No.: 14R0575