On March 16, 2022 a
Motion,Ex Parte
was filed
involving a dispute between
Cheryl Turner,
and
Community Counseling And Mediation,
Hayaa Snediker Llc,
for Real Property - Other (Nuisance)
in the District Court of Kings County.
Preview
FILED: KINGS COUNTY CLERK 05/09/2022 04:23 PM INDEX NO. 507841/2022
NYSCEF DOC. NO. 3 RECEIVED NYSCEF: 05/09/2022
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF KINGS
---------------------------------- x
CHERYL TURNER, : Index No. 507841/2022
:
Plaintiff, :
:
-against- : NOTICE OF MOTION
: TO DISMISS
COMMUNITY COUNSELING AND :
MEDIATION and HAYAA SNEDIKER LLC, :
:
Defendants. :
---------------------------------- X
PLEASE TAKE NOTICE that upon the annexed Affirmation of Tristan C. Loanzon, dated
May 9, 2022 with exhibits, and Memorandum of Law, dated May 9, 2022, and upon the pleadings
and prior proceedings had herein, co-Defendant Community Counseling and Mediation will move
this Court, at an IAS Part, 360 Adams Street, Brooklyn, New York on June 8, 2022 at 9:30
a.m. or as soon thereafter as counsel can be heard, for an order pursuant to C.P.L.R. § 3211(a)(1)
and (a)(7) dismissing the Complaint’s based on documentary evidence and for failure to state a
claim, and for such other relief the Court may deem just and proper.
Please take further notice that, in accordance with C.P.L.R. § 2214(b), all answering papers
shall be served upon the undersigned no later than seven (7) days prior to the hearing date.
DATED: New York, New York
May 9, 2022
LOANZON LLP
______________________________
By: Tristan C. Loanzon, Esq.
Attorneys for Community Counseling and Mediation
1345 Avenue of the Americas, Fl. 2
New York, NY 10105
(212) 760-1515
1 of 2
FILED: KINGS COUNTY CLERK 05/09/2022 04:23 PM INDEX NO. 507841/2022
NYSCEF DOC. NO. 3 RECEIVED NYSCEF: 05/09/2022
TO: Richard Paul Stone, Esq. (via NYSCEF)
1345 Avenue of the Americas, Suite 200
New York, NY 10105
(516) 642-1987
Attorneys for Plaintiff Cheryl Turner
2
2 of 2
Document Filed Date
May 09, 2022
Case Filing Date
March 16, 2022
Category
Real Property - Other (Nuisance)
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FILED: KINGS COUNTY CLERK 05/09/2022 04:23 PM INDEX NO. 507841/2022 NYSCEF DOC. NO. 3 RECEIVED NYSCEF: 05/09/2022 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF KINGS ---------------------------------- x CHERYL TURNER, : Index No. 507841/2022 : Plaintiff, : : -against- : NOTICE OF MOTION : TO DISMISS COMMUNITY COUNSELING AND : MEDIATION and HAYAA SNEDIKER LLC, : : Defendants. : ---------------------------------- X PLEASE TAKE NOTICE that upon the annexed Affirmation of Tristan C. Loanzon, dated May 9, 2022 with exhibits, and Memorandum of Law, dated May 9, 2022, and upon the pleadings and prior proceedings had herein, co-Defendant Community Counseling and Mediation will move this Court, at an IAS Part, 360 Adams Street, Brooklyn, New York on June 8, 2022 at 9:30 a.m. or as soon thereafter as counsel can be heard, for an order pursuant to C.P.L.R. § 3211(a)(1) and (a)(7) dismissing the Complaint’s based on documentary evidence and for failure to state a claim, and for such other relief the Court may deem just and proper. Please take further notice that, in accordance with C.P.L.R. § 2214(b), all answering papers shall be served upon the undersigned no later than seven (7) days prior to the hearing date. DATED: New York, New York May 9, 2022 LOANZON LLP ______________________________ By: Tristan C. Loanzon, Esq. Attorneys for Community Counseling and Mediation 1345 Avenue of the Americas, Fl. 2 New York, NY 10105 (212) 760-1515 1 of 2 FILED: KINGS COUNTY CLERK 05/09/2022 04:23 PM INDEX NO. 507841/2022 NYSCEF DOC. NO. 3 RECEIVED NYSCEF: 05/09/2022 TO: Richard Paul Stone, Esq. (via NYSCEF) 1345 Avenue of the Americas, Suite 200 New York, NY 10105 (516) 642-1987 Attorneys for Plaintiff Cheryl Turner 2 2 of 2