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  • Filiberta Gregorio v. Michael Loscerbo, City Of Newburgh Police Department, City Of Newburgh Torts - Motor Vehicle document preview
  • Filiberta Gregorio v. Michael Loscerbo, City Of Newburgh Police Department, City Of Newburgh Torts - Motor Vehicle document preview
  • Filiberta Gregorio v. Michael Loscerbo, City Of Newburgh Police Department, City Of Newburgh Torts - Motor Vehicle document preview
  • Filiberta Gregorio v. Michael Loscerbo, City Of Newburgh Police Department, City Of Newburgh Torts - Motor Vehicle document preview
  • Filiberta Gregorio v. Michael Loscerbo, City Of Newburgh Police Department, City Of Newburgh Torts - Motor Vehicle document preview
  • Filiberta Gregorio v. Michael Loscerbo, City Of Newburgh Police Department, City Of Newburgh Torts - Motor Vehicle document preview
						
                                

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FILED: ORANGE COUNTY CLERK 05/02/2018 04:55 PM INDEX NO. EF008385-2017 NYSCEF DOC. NO. 14 RECEIVED NYSCEF: 05/02/2018 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF ORANGE - â€â€â€â€â€â€â€â€â€â€â€â€ ——————— ---------------------------------------------------------------------------X Index #EF008385/2017 FILIBERTA GREGORIO, NOTICE OF MOTION Plaintiff, FOR SUMMARY -against- JUDGMENT MICHAEL LOSCERBO, CITY OF NEWBURGH POLICE DEPARTMENT and CITY OF NEWBURGH, Defendants. ---------------------------------------------------------------------------X COUNSEL: PLEASE TAKE NOTICE, that upon the annexed affirmation of HIRAM ANTHONY RALDIRIS dated May 2, 2018, and the Exhibits annexed thereto, and upon the pleadings and proceedings heretofore had herein, the undersigned will move this Court in the Motion Support office thereof to be held at the Courthouse located at 285 Main Street, in the County of Orange, o' City of Goshen and State of New York on the 30th day of May, 2018 at 9:30 clock. in the forenoon of that day or as soon thereafter as counsel can be heard for an Order granting summary judgment on liability pursuant to CPLR §3212 along with such other and further relief as to this Court may seem just, proper and equitable. PLEASE TAKE FURTHER NOTICE that pursuant to CPLR §2214(b) answering affidavits, if any, are required to be served upon the undersigned no later than seven (7) days prior to the return date of this Motion. Dated: Bronx, New York May 2, 2018 Filedin Orange County 05/02/2018 04:55:46 PM $45.00 1 Bk: of 51263 Pg: 1913 Index: 0 EF008385-2017 Clerk: JM FILED: ORANGE COUNTY CLERK 05/02/2018 04:55 PM INDEX NO. EF008385-2017 NYSCEF DOC. NO. 14 RECEIVED NYSCEF: 05/02/2018 Yours, etc. PEÑÀ & KAHN, PLLC Attorneys for Plaintiff 1250 Waters Place, Suite 901 Bronx, New York 10461 (718) 585-6551 Our File No. By: HIRAM RIS TO: HODGES WALSH & MESSEMER, LLP Attorneys for Defendants MICHAEL LOSCERBO, CITY OF NEWBURGH POLICE DEPARTMENT and CITY OF NEWBURGH 55 Church Street, Suite 211 White Plains, New York 10601 (914) 385-6000 I 2 of 3 FILED: ORANGE COUNTY CLERK 05/02/2018 04:55 PM INDEX NO. EF008385-2017 NYSCEF DOC. NO. 14 RECEIVED NYSCEF: 05/02/2018 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF ORANGE Index No.: EF008385/2017 FILIBERTA GREGORIO, Plaintiff, -against- MICHAEL LOSCERBO, CITY OF NEWBURGH POLICE DEPARTMENT and CITY OF NEWBURGH, Defendants. NOTICE OF MOTION FOR SUMMARY JUDGMENT, AFFIRMATION IN SUPPORT OF MOTION FOR SUMMARY JUDGMENT and MEMORANDUM OF LAW IN SUPPORT OF MOTION FOR SUMMARY PEÑA & c% KAHN, PLLC Attorneys for Plaintiff(s) Office and Post Office Address, Telephone 1250 Waters Place, Ste. 901 Bronx, New York 10461 Tel: (718) 585-6551 Fax: (718) 585-6618 Pursuant to 22NYCRR 130- the an admitted to practice in the 1.1, undersigned, attorney ' Courts of New York State, certifies that, upon inform n e le easonable inquiry, the contentions contained in the annexed docume re not frivolou IDANTHOkfEALDIRIS PEÑA .PENA 4 KAHN, PLLC [ ]Notice of Entry that the within is a (certified) true copy of a duly entered in the Office of the Clerk of the within named court on 20 [ ]Notice of Settlement that an order of which the within is a true copy will be presented to the Hon. one of the judges of the within court at on 20 at M. Dated: Yours, To: Pena & Kahn, PLLC 1250 Waters Place, Suite 901 Bronx, NY 10461. (718) 585-6551 3 of 3