Preview
FILED: QUEENS COUNTY CLERK 08/21/2019 10:59 AM INDEX NO. 703719/2018
NYSCEF DOC. NO. 19 RECEIVED NYSCEF: 08/21/2019
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,
NOTICE OF MOTION
FOR DEFAULT
Plaintiffs, JUDGMENT
-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 the 20th day of August,
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 Boulevard, Jamaica, NY 11435, Part 19, Courtroom 44A, in front of the Honorable Pam
30th
Jackman Brown, on the day of September, 2019 at 9:30am in the forenoon of that day or as
soon thereafter as counsel can be heard:
For an order pursuant to Section 3215 of the Civil Practice Law and Rules directing the
entry of judgment upon default in favor of plaintiff and against all defendants, 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.
1 of 4
FILED: QUEENS COUNTY CLERK 08/21/2019 10:59 AM INDEX NO. 703719/2018
NYSCEF DOC. NO. 19 RECEIVED NYSCEF: 08/21/2019
TAKE FURTHER NOTICE that,pursuant to Section 2214(b) of the Civil Practice Law
and Rules, all answering papers, ifany, shall be served at least seven (7) days before the return
date of this motion.
Dated: Astoria, New York
August 20, 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 08/21/2019 10:59 AM INDEX NO. 703719/2018
NYSCEF DOC. NO. 19 RECEIVED NYSCEF: 08/21/2019
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
On 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
to before e
O
LIC Mario
Notary Garcia
Public,Stateof
NewYork
ouaÏifleÈin
commission oex ~
Expires county
9eptember
7
80, 20
=
3 of 4
FILED: QUEENS COUNTY CLERK 08/21/2019 10:59 AM INDEX NO. 703719/2018
NYSCEF DOC. NO. 19 RECEIVED NYSCEF: 08/21/2019
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,
Plaintiffs,
-against-
JEVAN SIMPSON, KAYDE PALMER AND FAST LANE MOTORS, LLC,
Defendants.
___________________________________.________________
NOTICE OF MOTION FOR DEFAULT JUDGMENT, SUPPORTING AFFIRMATION,
SUPPORTING AFFIDAVIT and REQUEST FOR JUDICIAL INTERVENTION
_______________.___________________________________
Pursuant to 22 NYCRR 130-1.1, the undersigned, an attorney admitted to practice in the courts
of New York State, certifies that, upon information and belief and reasonable inquiry, the
contentions contained in the annexed documents are not frivolous.
Dated: Astoria, NY
August 20, 2019
Si ture
By: Eric S. Cantor
SACCO & FILLAS, LLP
Attorneys for Plaintiff
Rayna E. Douglas
31-19 Newtown Avenue
Seventh Floor
Astoria, New York 11102
(718) 746-3440
Our File # 20009-17
4 of 4
Preview
FILED: QUEENS COUNTY CLERK 08/21/2019 10:59 AM INDEX NO. 703719/2018 NYSCEF DOC. NO. 19 RECEIVED NYSCEF: 08/21/2019 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, NOTICE OF MOTION FOR DEFAULT Plaintiffs, JUDGMENT -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 the 20th day of August, 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 Boulevard, Jamaica, NY 11435, Part 19, Courtroom 44A, in front of the Honorable Pam 30th Jackman Brown, on the day of September, 2019 at 9:30am in the forenoon of that day or as soon thereafter as counsel can be heard: For an order pursuant to Section 3215 of the Civil Practice Law and Rules directing the entry of judgment upon default in favor of plaintiff and against all defendants, 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. 1 of 4 FILED: QUEENS COUNTY CLERK 08/21/2019 10:59 AM INDEX NO. 703719/2018 NYSCEF DOC. NO. 19 RECEIVED NYSCEF: 08/21/2019 TAKE FURTHER NOTICE that,pursuant to Section 2214(b) of the Civil Practice Law and Rules, all answering papers, ifany, shall be served at least seven (7) days before the return date of this motion. Dated: Astoria, New York August 20, 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 08/21/2019 10:59 AM INDEX NO. 703719/2018 NYSCEF DOC. NO. 19 RECEIVED NYSCEF: 08/21/2019 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 On 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 to before e O LIC Mario Notary Garcia Public,Stateof NewYork ouaÏifleÈin commission oex ~ Expires county 9eptember 7 80, 20 = 3 of 4 FILED: QUEENS COUNTY CLERK 08/21/2019 10:59 AM INDEX NO. 703719/2018 NYSCEF DOC. NO. 19 RECEIVED NYSCEF: 08/21/2019 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, Plaintiffs, -against- JEVAN SIMPSON, KAYDE PALMER AND FAST LANE MOTORS, LLC, Defendants. ___________________________________.________________ NOTICE OF MOTION FOR DEFAULT JUDGMENT, SUPPORTING AFFIRMATION, SUPPORTING AFFIDAVIT and REQUEST FOR JUDICIAL INTERVENTION _______________.___________________________________ Pursuant to 22 NYCRR 130-1.1, the undersigned, an attorney admitted to practice in the courts of New York State, certifies that, upon information and belief and reasonable inquiry, the contentions contained in the annexed documents are not frivolous. Dated: Astoria, NY August 20, 2019 Si ture By: Eric S. Cantor SACCO & FILLAS, LLP Attorneys for Plaintiff Rayna E. Douglas 31-19 Newtown Avenue Seventh Floor Astoria, New York 11102 (718) 746-3440 Our File # 20009-17 4 of 4