On December 02, 2019 a
Motion,Ex Parte
was filed
involving a dispute between
American Express National Bank,
and
Mbr Medical Beauty Research Usa L.L.C.,
for Commercial - Contract
in the District Court of New York County.
Preview
FILED: NEW YORK COUNTY CLERK 03/17/2020 10:49 AM INDEX NO. 657114/2019
NYSCEF DOC. NO. 9 RECEIVED NYSCEF: 03/17/2020
SUPREME COURT OF THE STATE OF NEW YORK Motion Sequence # _______
COUNTY OF NEW YORK Motion Calendar # _______
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AMERICAN EXPRESS NATIONAL BANK,
NOTICE OF MOTION FOR
Plaintiff, DEFAULT JUDGMENT
-against-
Index Number: 657114/2019
MBR MEDICAL BEAUTY RESEARCH USA
L.L.C.,
Defendant.
-----------------------------------------------------------------X
PLEASE TAKE NOTICE that upon the annexed affidavit of Plaintiff, and the exhibits
attached thereto, as well as all the other supporting documentation that is enclosed herewith, and
upon all the prior pleadings and proceedings in this case to date, Plaintiff will move before this
Court, which is located at 60 Centre Street, Room 130 (the Motion Submissions Part Courtroom),
New York, New York 10007, on April 29, 2020, at 9:30 a.m., or as soon thereafter as Plaintiff can
be heard, for an Order, pursuant to CPLR 3215, granting the following relief:
(1) Directing the clerk to enter default judgment in favor of Plaintiff, and against
Defendant(s), in the amount of $312,281.26;
(2) Directing the clerk to add the costs and disbursements of this action onto the
aforementioned judgment amount, and to tax said amounts to Defendant(s); and
(3) Any additional relief that the Court may deem just and proper in light of the
procedural and substantive history of this matter.
PLEASE TAKE FURTHER NOTICE that, pursuant to CPLR 2214 (b), these papers
have been served on you at least sixteen (16) days before this motion is scheduled to be heard.
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FILED: NEW YORK COUNTY CLERK 03/17/2020 10:49 AM INDEX NO. 657114/2019
NYSCEF DOC. NO. 9 RECEIVED NYSCEF: 03/17/2020
Therefore, if you choose to file answering papers, then you must serve your answering papers on
our office at least seven (7) days before said date (i.e., the date on which this motion is scheduled
to be heard).
Dated: Piscataway, New Jersey /s/ Carl E. Zapffe s
March 17, 2020 Carl E. Zapffe, Esq.
ZWICKER & ASSOCIATES, P.C.
A Law Firm Engaged in Debt Collection
1551 South Washington Avenue, Suite 404
Piscataway Township, NJ 08854
855-427-7433 (Phone)
LitigationZAPC@zwickerpc.com
New York Office (for compliance purposes):
100 Corporate Woods, Suite 230
Rochester, NY 14623
To: MBR Medical Beauty Research USA L.L.C.
c/o Agent: Registered Agents Inc.
401 Ryland Street, Suite 200-A
Reno, NV 89502
MBR Medical Beauty Research USA L.L.C.
8484 Wilshire Boulevard, Suite 540
Beverly Hills, CA 90211
2 of 2
Document Filed Date
March 17, 2020
Case Filing Date
December 02, 2019
Category
Commercial - Contract
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Preview
FILED: NEW YORK COUNTY CLERK 03/17/2020 10:49 AM INDEX NO. 657114/2019 NYSCEF DOC. NO. 9 RECEIVED NYSCEF: 03/17/2020 SUPREME COURT OF THE STATE OF NEW YORK Motion Sequence # _______ COUNTY OF NEW YORK Motion Calendar # _______ -----------------------------------------------------------------X AMERICAN EXPRESS NATIONAL BANK, NOTICE OF MOTION FOR Plaintiff, DEFAULT JUDGMENT -against- Index Number: 657114/2019 MBR MEDICAL BEAUTY RESEARCH USA L.L.C., Defendant. -----------------------------------------------------------------X PLEASE TAKE NOTICE that upon the annexed affidavit of Plaintiff, and the exhibits attached thereto, as well as all the other supporting documentation that is enclosed herewith, and upon all the prior pleadings and proceedings in this case to date, Plaintiff will move before this Court, which is located at 60 Centre Street, Room 130 (the Motion Submissions Part Courtroom), New York, New York 10007, on April 29, 2020, at 9:30 a.m., or as soon thereafter as Plaintiff can be heard, for an Order, pursuant to CPLR 3215, granting the following relief: (1) Directing the clerk to enter default judgment in favor of Plaintiff, and against Defendant(s), in the amount of $312,281.26; (2) Directing the clerk to add the costs and disbursements of this action onto the aforementioned judgment amount, and to tax said amounts to Defendant(s); and (3) Any additional relief that the Court may deem just and proper in light of the procedural and substantive history of this matter. PLEASE TAKE FURTHER NOTICE that, pursuant to CPLR 2214 (b), these papers have been served on you at least sixteen (16) days before this motion is scheduled to be heard. 1 of 2 FILED: NEW YORK COUNTY CLERK 03/17/2020 10:49 AM INDEX NO. 657114/2019 NYSCEF DOC. NO. 9 RECEIVED NYSCEF: 03/17/2020 Therefore, if you choose to file answering papers, then you must serve your answering papers on our office at least seven (7) days before said date (i.e., the date on which this motion is scheduled to be heard). Dated: Piscataway, New Jersey /s/ Carl E. Zapffe s March 17, 2020 Carl E. Zapffe, Esq. ZWICKER & ASSOCIATES, P.C. A Law Firm Engaged in Debt Collection 1551 South Washington Avenue, Suite 404 Piscataway Township, NJ 08854 855-427-7433 (Phone) LitigationZAPC@zwickerpc.com New York Office (for compliance purposes): 100 Corporate Woods, Suite 230 Rochester, NY 14623 To: MBR Medical Beauty Research USA L.L.C. c/o Agent: Registered Agents Inc. 401 Ryland Street, Suite 200-A Reno, NV 89502 MBR Medical Beauty Research USA L.L.C. 8484 Wilshire Boulevard, Suite 540 Beverly Hills, CA 90211 2 of 2