On March 07, 2018 a
Motion,Ex Parte
was filed
involving a dispute between
Moustafa Ibrahim,
and
Qing Sun,
for Torts - Other (Trip and Fall)
in the District Court of Queens County.
Preview
FILED: QUEENS COUNTY CLERK 04/24/2019 04:53 PM INDEX NO. 703522/2018
NYSCEF DOC. NO. 8 RECEIVED NYSCEF: 04/24/2019
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY QUEENS
---------------------------- --------X INDEX NO.: 703522/18E
MOUSTAFA IBRAHIM,
Plaintiff,
- against - NOTICE OF MOTION
QING SUN,
FILE NO. 1009896
Defendant.
------------ ------- ¬-----------------X
C O U N S E L O R:
PLEASE TAKE NOTICE that upon the annexed Affirmation of SUMMER TINNIE,
ESQ., dated April 19, 2019, the Affirmation of Darren Fitzpatrick, M.D., dated October 17,
2018, the Affirmation of Thomas Nipper, M.D., dated April 3, 2019, and allprior pleadings and
proceedings in the above matter, the undersigned will move before the Honorable Fredrick D.R.
Sampson at the courthouse located at 25-10 Court Square, Long Island City, New York, 11101,
Room # 208 on the 16*of May 2019, at 9: 30 a.m., be heard for an Order pursuant to CPLR §
3212 granting defendants summary judgment and dismissing the Complaint of plaintiff, in as
much as plaintiff, MOUSTAFA IBRAHIM fails to meet the serious injury threshold requirement
mandated by Insurance Law § 5102 (d) and granting such other further relief as the Court deems
just and proper.
PLEASE TAKE FURTHER NOTICE, that pursuant to CPLR § 2214(b), all answering
papers and notice of cross-motion, with supporting papers, if any, must be served at least seven
(7) days prior to the return date of this motion.
Dated: Brooklyn, New York
April 19, 2019
Yo etc.,
B M , ORRISSEY
& MOS S, P.C.
By: INNIE ..
At eys for Defendant
QING SUN
8*
1 Metrotech Center, Floor,
Brooklyn, New York 11201
(212) 497-1685
1
1 of 2
FILED: QUEENS COUNTY CLERK 04/24/2019 04:53 PM INDEX NO. 703522/2018
NYSCEF DOC. NO. 8 RECEIVED NYSCEF: 04/24/2019
TO: LAW OFFIE OF GEORGE A. CONSTANTINE, P.C.,
Attorneys for Plaintif
MOUSTAFA IBRAHIM
265 Post Avenue, Suite 112,
Westbury, NY, 11590
(718) 707-2915
2
2 of 2
Document Filed Date
April 24, 2019
Case Filing Date
March 07, 2018
Category
Torts - Other (Trip and Fall)
For full print and download access, please subscribe at https://www.trellis.law/.
Preview
FILED: QUEENS COUNTY CLERK 04/24/2019 04:53 PM INDEX NO. 703522/2018 NYSCEF DOC. NO. 8 RECEIVED NYSCEF: 04/24/2019 SUPREME COURT OF THE STATE OF NEW YORK COUNTY QUEENS ---------------------------- --------X INDEX NO.: 703522/18E MOUSTAFA IBRAHIM, Plaintiff, - against - NOTICE OF MOTION QING SUN, FILE NO. 1009896 Defendant. ------------ ------- ¬-----------------X C O U N S E L O R: PLEASE TAKE NOTICE that upon the annexed Affirmation of SUMMER TINNIE, ESQ., dated April 19, 2019, the Affirmation of Darren Fitzpatrick, M.D., dated October 17, 2018, the Affirmation of Thomas Nipper, M.D., dated April 3, 2019, and allprior pleadings and proceedings in the above matter, the undersigned will move before the Honorable Fredrick D.R. Sampson at the courthouse located at 25-10 Court Square, Long Island City, New York, 11101, Room # 208 on the 16*of May 2019, at 9: 30 a.m., be heard for an Order pursuant to CPLR § 3212 granting defendants summary judgment and dismissing the Complaint of plaintiff, in as much as plaintiff, MOUSTAFA IBRAHIM fails to meet the serious injury threshold requirement mandated by Insurance Law § 5102 (d) and granting such other further relief as the Court deems just and proper. PLEASE TAKE FURTHER NOTICE, that pursuant to CPLR § 2214(b), all answering papers and notice of cross-motion, with supporting papers, if any, must be served at least seven (7) days prior to the return date of this motion. Dated: Brooklyn, New York April 19, 2019 Yo etc., B M , ORRISSEY & MOS S, P.C. By: INNIE .. At eys for Defendant QING SUN 8* 1 Metrotech Center, Floor, Brooklyn, New York 11201 (212) 497-1685 1 1 of 2 FILED: QUEENS COUNTY CLERK 04/24/2019 04:53 PM INDEX NO. 703522/2018 NYSCEF DOC. NO. 8 RECEIVED NYSCEF: 04/24/2019 TO: LAW OFFIE OF GEORGE A. CONSTANTINE, P.C., Attorneys for Plaintif MOUSTAFA IBRAHIM 265 Post Avenue, Suite 112, Westbury, NY, 11590 (718) 707-2915 2 2 of 2