On October 08, 2013 a
Motion,Ex Parte
was filed
involving a dispute between
Express Trade Capital, Inc.,
Peter Stern,
and
Air Cargo Services, Llc,
Delex Air Cargo Llc.,
Delex Inc.,
Oleg Ardachev,
for Commercial (General)
in the District Court of New York County.
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FILED: NEW YORK COUNTY CLERK 01/24/2018 05:03 PM INDEX NO. 653476/2013
NYSCEF DOC. NO. 134 RECEIVED NYSCEF: 01/24/2018
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF NEW YORK
----- ----------"-""-----
------------------------------------x
:
PETER STERN and EXPRESS TRADE CAPITAL,
INC., : Index No. 653476/13
Plaintiffs, : NOTICE OF MOTION FOR
LEAVE TO FILE AN
-against- : AMENDED COMPLAINT
OLEG ARDACHEV, AIR CARGO SERVICES L.L.C., :
DELEX INC., DELEX AIR CARGO, LLC, a Delaware
limited liability company, and DELEX AIR CARGO, :
LLC, a Washington limited liability company,
:
Defendants.
-""----------------- x
PLEASE TAKE NOTICE that upon the annexed Affirmation of Lon J. Seidman, dated
January 24, 2018, and the exhibits thereto, and the accompanying Memorandum of Law and
upon all prior papers and proceedings heretofore had herein, Diamond McCarthy LLP, attorneys
for plaintiffs Peter Stern and Express Trade Capital Inc., will move this Court at Room 130, 60
Centre Street, New York, New York 10007, on the 2nd day of February, 2018, at 9:30 a.m., or as
soon thereafter as counsel can be heard, for an order pursuant to CPLR 3025(b) granting the
1 of 2
FILED: NEW YORK COUNTY CLERK 01/24/2018 05:03 PM INDEX NO. 653476/2013
NYSCEF DOC. NO. 134 RECEIVED NYSCEF: 01/24/2018
plaintiffs leave to file the proposed amended complaint annexed to the Affirmation of Lon J.
Seidman, and granting such other and further relief as may be just and proper under the
circumstance.
Dated: New York, New York
January 24, 2018
DIAMOND McCARTHY LLP
Lof dman, Esq.
21't
489 riAvenue, Floor
New York, New York 10017
Tel.: (212) 430-5400
Fax: (212) 430-5499
lseidman@diamondmccarthy.com
TO: Robert Bondar, Esq.
Attorney for Defendants
28 Dooley Street, 3rd Fl.
Brooklyn, NY 11235
2
2 of 2
Document Filed Date
January 24, 2018
Case Filing Date
October 08, 2013
Category
Commercial (General)
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FILED: NEW YORK COUNTY CLERK 01/24/2018 05:03 PM INDEX NO. 653476/2013 NYSCEF DOC. NO. 134 RECEIVED NYSCEF: 01/24/2018 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF NEW YORK ----- ----------"-""----- ------------------------------------x : PETER STERN and EXPRESS TRADE CAPITAL, INC., : Index No. 653476/13 Plaintiffs, : NOTICE OF MOTION FOR LEAVE TO FILE AN -against- : AMENDED COMPLAINT OLEG ARDACHEV, AIR CARGO SERVICES L.L.C., : DELEX INC., DELEX AIR CARGO, LLC, a Delaware limited liability company, and DELEX AIR CARGO, : LLC, a Washington limited liability company, : Defendants. -""----------------- x PLEASE TAKE NOTICE that upon the annexed Affirmation of Lon J. Seidman, dated January 24, 2018, and the exhibits thereto, and the accompanying Memorandum of Law and upon all prior papers and proceedings heretofore had herein, Diamond McCarthy LLP, attorneys for plaintiffs Peter Stern and Express Trade Capital Inc., will move this Court at Room 130, 60 Centre Street, New York, New York 10007, on the 2nd day of February, 2018, at 9:30 a.m., or as soon thereafter as counsel can be heard, for an order pursuant to CPLR 3025(b) granting the 1 of 2 FILED: NEW YORK COUNTY CLERK 01/24/2018 05:03 PM INDEX NO. 653476/2013 NYSCEF DOC. NO. 134 RECEIVED NYSCEF: 01/24/2018 plaintiffs leave to file the proposed amended complaint annexed to the Affirmation of Lon J. Seidman, and granting such other and further relief as may be just and proper under the circumstance. Dated: New York, New York January 24, 2018 DIAMOND McCARTHY LLP Lof dman, Esq. 21't 489 riAvenue, Floor New York, New York 10017 Tel.: (212) 430-5400 Fax: (212) 430-5499 lseidman@diamondmccarthy.com TO: Robert Bondar, Esq. Attorney for Defendants 28 Dooley Street, 3rd Fl. Brooklyn, NY 11235 2 2 of 2