Preview
FILED: QUEENS COUNTY CLERK 04/30/2019 11:20 AM INDEX NO. 703719/2018
NYSCEF DOC. NO. 10 RECEIVED NYSCEF: 04/30/2019
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF QUEENS
G.B., an infant by his mother and natural guardian RAYNA
DOUGLAS and RAYNA DOUGLAS, Individual,
NOTICE OF MOTION
FOR DEFAULT
Plaintiffs, WDGMENT
-against-
JEVAN SIMPSON, KAYDE PALMER AND FAST LANE
MOTORS, LLC,
Defendants.
C O U N S E L O R S :
PLEASE TAKE NOTICE, that upon the annexed affidavit of Rayna E. Douglas, sworn
19th
to the day of April, 2019, the affirmation of Eric S. Cantor, dated the26th day of April, 2019,
and upon all the pleadings and proceedings heretofore had herein, the undersigned will move
before this Court at the Courthouse located at Supreme Court, Queens County, 88-11 Sutphin
28th
Boulevard, Jamaica, NY 1I435, on the day of May, 2019 at 9:30am in the forenoon of that
day or as soon thereafter as counsel can be heard:
For an order pursuãñt to Section 3215 of the Civil Practice Law and Rules directing the
entry of judgment upon default in favor of plaintiff and against all defendãñts, on the issue of
liability and setting the matter down for an inquest as to damages, for an award of costs,
disbursements and reasonable attorney's fees to abide this motion, and for such other and further
relief as to this Court may seem just and proper.
The above-entitled action is for personal injuries. This action is not on the trial calendar.
TAKE FURTHER NOTICE that, pursuant to Section 2214(b) of the Civil Practice Law
1 of 4
FILED: QUEENS COUNTY CLERK 04/30/2019 11:20 AM INDEX NO. 703719/2018
NYSCEF DOC. NO. 10 RECEIVED NYSCEF: 04/30/2019
and Rules, allanswering papers, if any, shall be served at least seven (7) days before the return
date of this motion.
Dated: Astoria, New York
April 26, 2019
By: Eric S. Cantor, Esq.
SACCO & FILLAS, LLP
Attorneys for Plaintiff
31-19 Newtown Avenue
Seventh Floor
Astoria, New York 11102
(718) 746-3440
Our File # 20009-17
TO:
DEFENDANTS (see affidavit of service)
2 of 4
FILED: QUEENS COUNTY CLERK 04/30/2019 11:20 AM INDEX NO. 703719/2018
NYSCEF DOC. NO. 10 RECEIVED NYSCEF: 04/30/2019
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF QUEENS
INDEX NO. 703719/2018
G.B., an infant by his mother and natural guardian RAYNA
DOUGLAS and RAYNA DOUGLAS, Individual,
AFFIDAVIT OF MAIL
Plaintiffs, SERVICE
-against-
JEVAN SIMPSON, KAYDE PALMER AND FAST LANE
MOTORS, LLC,
Defendants.
STATE OF NEW YORK
COUNTY OF QUEENS
Zachary Zain, being duly sworn, says:
I am not a party to the action; I reside in Astoria, New York, and I am over 18 years of
age.
On April 30, 2019 I served the within Notice of Motion for Default Judgment together
with Supporting Affidavit and Affirmation, and Request for Judicial Intervention by depositing
true copies thereof, enclosed in a post-paid wrapper, in an official depository under the
exclusive care and custody of the United States Postal Service within New York State,
addressed to the following at the last known address set forth below:
Jevan Simpson Fast Lane Motors, LLC
209th 2nd
114-36 Street 3291 Ne Avenue Bay 13
Cambria Heights, New York 11411 Oakland Park FL, 33334
Kayde Palmer
209th
114-36 Street
Cambria Heights, New York 11411
Zac)/dry Zain
Sworn to before me
On April 30, 2019
NOTARY PUBLIC
Mario Garcia
NotaryPublic, Stateof New York
No.
01GA6289787
Qualifiedin Bronx
Comi ssion County
Expires )
September 30, 20 _
3 of 4
FILED: QUEENS COUNTY CLERK 04/30/2019 11:20 AM INDEX NO. 703719/2018
NYSCEF DOC. NO. 10 RECEIVED NYSCEF: 04/30/2019
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF QUEENS
Index No. 703719/2018
- ___ __ - _ - - - - - - _ _ _ _ _ _ _ _ _ _ _ - __ _ _ _ - - - - - - - - - - - - - - __ - - - -
G.B., an infant by his mother and natural guardian RAYNA DOUGLAS an
DOUGLAS, Individual,
Plaintiffs,
-against-
JEVAN SIMPSON, KAYDE PALMER AND FAST LANE MOTORS, LL
Defendants.
____________________________________________.______
NOTICE OF MOTION FOR DEFAULT JUDGMENT, SUPPORTING
SUPPORTING AFFIDAVIT and REQUEST FOR JUDICIAL INT
___________________ ___ ____________________________
Pursuant to 22 NYCRR 130-1.1, the ündersigned, an attorney admitted to
of New York State, certifies that, upon information and belief and reasonable
contentions contained in the annexed documents are not frivolous.
Dated: Astoria, NY
April 26, 2019
S ignatu e:
By: Eric S. Cantor
4 of 4
Preview
FILED: QUEENS COUNTY CLERK 04/30/2019 11:20 AM INDEX NO. 703719/2018 NYSCEF DOC. NO. 10 RECEIVED NYSCEF: 04/30/2019 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF QUEENS G.B., an infant by his mother and natural guardian RAYNA DOUGLAS and RAYNA DOUGLAS, Individual, NOTICE OF MOTION FOR DEFAULT Plaintiffs, WDGMENT -against- JEVAN SIMPSON, KAYDE PALMER AND FAST LANE MOTORS, LLC, Defendants. C O U N S E L O R S : PLEASE TAKE NOTICE, that upon the annexed affidavit of Rayna E. Douglas, sworn 19th to the day of April, 2019, the affirmation of Eric S. Cantor, dated the26th day of April, 2019, and upon all the pleadings and proceedings heretofore had herein, the undersigned will move before this Court at the Courthouse located at Supreme Court, Queens County, 88-11 Sutphin 28th Boulevard, Jamaica, NY 1I435, on the day of May, 2019 at 9:30am in the forenoon of that day or as soon thereafter as counsel can be heard: For an order pursuãñt to Section 3215 of the Civil Practice Law and Rules directing the entry of judgment upon default in favor of plaintiff and against all defendãñts, on the issue of liability and setting the matter down for an inquest as to damages, for an award of costs, disbursements and reasonable attorney's fees to abide this motion, and for such other and further relief as to this Court may seem just and proper. The above-entitled action is for personal injuries. This action is not on the trial calendar. TAKE FURTHER NOTICE that, pursuant to Section 2214(b) of the Civil Practice Law 1 of 4 FILED: QUEENS COUNTY CLERK 04/30/2019 11:20 AM INDEX NO. 703719/2018 NYSCEF DOC. NO. 10 RECEIVED NYSCEF: 04/30/2019 and Rules, allanswering papers, if any, shall be served at least seven (7) days before the return date of this motion. Dated: Astoria, New York April 26, 2019 By: Eric S. Cantor, Esq. SACCO & FILLAS, LLP Attorneys for Plaintiff 31-19 Newtown Avenue Seventh Floor Astoria, New York 11102 (718) 746-3440 Our File # 20009-17 TO: DEFENDANTS (see affidavit of service) 2 of 4 FILED: QUEENS COUNTY CLERK 04/30/2019 11:20 AM INDEX NO. 703719/2018 NYSCEF DOC. NO. 10 RECEIVED NYSCEF: 04/30/2019 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF QUEENS INDEX NO. 703719/2018 G.B., an infant by his mother and natural guardian RAYNA DOUGLAS and RAYNA DOUGLAS, Individual, AFFIDAVIT OF MAIL Plaintiffs, SERVICE -against- JEVAN SIMPSON, KAYDE PALMER AND FAST LANE MOTORS, LLC, Defendants. STATE OF NEW YORK COUNTY OF QUEENS Zachary Zain, being duly sworn, says: I am not a party to the action; I reside in Astoria, New York, and I am over 18 years of age. On April 30, 2019 I served the within Notice of Motion for Default Judgment together with Supporting Affidavit and Affirmation, and Request for Judicial Intervention by depositing true copies thereof, enclosed in a post-paid wrapper, in an official depository under the exclusive care and custody of the United States Postal Service within New York State, addressed to the following at the last known address set forth below: Jevan Simpson Fast Lane Motors, LLC 209th 2nd 114-36 Street 3291 Ne Avenue Bay 13 Cambria Heights, New York 11411 Oakland Park FL, 33334 Kayde Palmer 209th 114-36 Street Cambria Heights, New York 11411 Zac)/dry Zain Sworn to before me On April 30, 2019 NOTARY PUBLIC Mario Garcia NotaryPublic, Stateof New York No. 01GA6289787 Qualifiedin Bronx Comi ssion County Expires ) September 30, 20 _ 3 of 4 FILED: QUEENS COUNTY CLERK 04/30/2019 11:20 AM INDEX NO. 703719/2018 NYSCEF DOC. NO. 10 RECEIVED NYSCEF: 04/30/2019 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF QUEENS Index No. 703719/2018 - ___ __ - _ - - - - - - _ _ _ _ _ _ _ _ _ _ _ - __ _ _ _ - - - - - - - - - - - - - - __ - - - - G.B., an infant by his mother and natural guardian RAYNA DOUGLAS an DOUGLAS, Individual, Plaintiffs, -against- JEVAN SIMPSON, KAYDE PALMER AND FAST LANE MOTORS, LL Defendants. ____________________________________________.______ NOTICE OF MOTION FOR DEFAULT JUDGMENT, SUPPORTING SUPPORTING AFFIDAVIT and REQUEST FOR JUDICIAL INT ___________________ ___ ____________________________ Pursuant to 22 NYCRR 130-1.1, the ündersigned, an attorney admitted to of New York State, certifies that, upon information and belief and reasonable contentions contained in the annexed documents are not frivolous. Dated: Astoria, NY April 26, 2019 S ignatu e: By: Eric S. Cantor 4 of 4