On February 28, 2014 a
Motion,Ex Parte
was filed
involving a dispute between
Terence Cardinal Cooke Nursing Home,
and
Robert Rohr,
for Contract (Non-Commercial)
in the District Court of New York County.
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INDEX NO. 151788/2014
FILED: NEW YORK COUNTY CLERK 0471872014
NYSCEF boc. No. 8 RECEIVED NYSCEF 04/18/2014
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF NEW YORK
wanna nana wane ee
TERENCE CARDINAL COOKE NURSING HOME, Index No.: 151788/14
Plaintiff, NOTICE OF MOTION
FOR SUMMARY
JUDGMENT
- against -
ROBERT ROHR,
Defendant.
aa nnn
PLEASE TAKE NOTICE, that upon the annexed Affidavit of Annmarie Covone sworn
to on April 8, 2014 and the exhibits annexed thereto, the Affirmation of Shelby E. Neiss, an
associate attorney with Wolf Haldenstein Adler Freeman and Herz, LLP, attorneys for Plaintiff,
dated April 11, 2014, and the exhibits annexed thereto, the Summons and Complaint, the
Answer, and upon all of the proceedings had herein, Plaintiff will move this Court located in
Room 130, 60 Centre Street, New York, New York, on the 9" day of May, 2014, 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 Rule 3212 directing the entry of Summary Judgment for Plaintiff upon the causes of
action set forth in the Complaint, and for such other and further relief as this Court may deem
just and proper.
PLEASE TAKE FURTHER NOTICE that answering papers, if any, must be served upon
the undersigned pursuant to CPLR § 2214(b).
DATED: New York, New York
April 11, 2014
LAW OFFICE OF
WOLF HALDENSTEIN ADLER
FREEMAN,-& HERZ LL Pe
By ~
Shelby E-Neiss.
Attorneys for Plaintiff
Office & Post Office Address
270 Madison Avenue
New York, New York 10016
(212) 545-4600
TO: ROBERT ROHR
Defendant, Pro Se
310 W. 7. ard
3" Street, Apt. B
New York, New York 10023
-2
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF NEW YOR! No. 151788/14
a eo Lea as
TERENCE CARDINAL COOKE
NURSING HOME,
Plaintiff,
-against-
ROBERT ROHR,
Defendant,
a wae
NOTICE OF MOTION FOR SUMMARY JUDGMENT
noon
Wor HALDENSTEIN ADLER FREEMAN & HERZ LLP
Attorneys for Plaintiff
270 MADISON AVENUE
NEW YORK,NY 10016
212-545-4600
— = = = cere seen ———.
=
To: Service of a copy of the within
is hereby admitted.
Dated: 20
Attorney(s) for
- _e eo. nese ae a eee ere
PLEASE TAKE NOTICE:
(NOTICE
OF ENTRY
that the within is a (certified) true copy of an
duly entered in the office of the clerk of the within named court on 20
(2 NOTICE
OF SETTLEMENT
that an , of which the within is a true copy,
will presented for settlement to the Hon. .one of the judges of the
within named Court, at
on 20 vat
Dated:
WOLF HALDENSTEIN ADLER FREEMAN & HERZ LLP
Document Filed Date
April 18, 2014
Case Filing Date
February 28, 2014
Category
Contract (Non-Commercial)
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INDEX NO. 151788/2014 FILED: NEW YORK COUNTY CLERK 0471872014 NYSCEF boc. No. 8 RECEIVED NYSCEF 04/18/2014 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF NEW YORK wanna nana wane ee TERENCE CARDINAL COOKE NURSING HOME, Index No.: 151788/14 Plaintiff, NOTICE OF MOTION FOR SUMMARY JUDGMENT - against - ROBERT ROHR, Defendant. aa nnn PLEASE TAKE NOTICE, that upon the annexed Affidavit of Annmarie Covone sworn to on April 8, 2014 and the exhibits annexed thereto, the Affirmation of Shelby E. Neiss, an associate attorney with Wolf Haldenstein Adler Freeman and Herz, LLP, attorneys for Plaintiff, dated April 11, 2014, and the exhibits annexed thereto, the Summons and Complaint, the Answer, and upon all of the proceedings had herein, Plaintiff will move this Court located in Room 130, 60 Centre Street, New York, New York, on the 9" day of May, 2014, 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 Rule 3212 directing the entry of Summary Judgment for Plaintiff upon the causes of action set forth in the Complaint, and for such other and further relief as this Court may deem just and proper. PLEASE TAKE FURTHER NOTICE that answering papers, if any, must be served upon the undersigned pursuant to CPLR § 2214(b). DATED: New York, New York April 11, 2014 LAW OFFICE OF WOLF HALDENSTEIN ADLER FREEMAN,-& HERZ LL Pe By ~ Shelby E-Neiss. Attorneys for Plaintiff Office & Post Office Address 270 Madison Avenue New York, New York 10016 (212) 545-4600 TO: ROBERT ROHR Defendant, Pro Se 310 W. 7. ard 3" Street, Apt. B New York, New York 10023 -2 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF NEW YOR! No. 151788/14 a eo Lea as TERENCE CARDINAL COOKE NURSING HOME, Plaintiff, -against- ROBERT ROHR, Defendant, a wae NOTICE OF MOTION FOR SUMMARY JUDGMENT noon Wor HALDENSTEIN ADLER FREEMAN & HERZ LLP Attorneys for Plaintiff 270 MADISON AVENUE NEW YORK,NY 10016 212-545-4600 — = = = cere seen ———. = To: Service of a copy of the within is hereby admitted. Dated: 20 Attorney(s) for - _e eo. nese ae a eee ere PLEASE TAKE NOTICE: (NOTICE OF ENTRY that the within is a (certified) true copy of an duly entered in the office of the clerk of the within named court on 20 (2 NOTICE OF SETTLEMENT that an , of which the within is a true copy, will presented for settlement to the Hon. .one of the judges of the within named Court, at on 20 vat Dated: WOLF HALDENSTEIN ADLER FREEMAN & HERZ LLP