On April 12, 2021 a
Motion,Ex Parte
was filed
involving a dispute between
Chrystal Peart,
Wade S. Williams,
and
Ean Holdings Llc,
John Doe, Said Name Is Being Fictitious And Unknown,
for Torts - Motor Vehicle
in the District Court of Kings County.
Preview
FILED: KINGS COUNTY CLERK 08/01/2022 12:26 PM INDEX NO. 508561/2021
NYSCEF DOC. NO. 74 RECEIVED NYSCEF: 08/01/2022
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF KINGS
_________________________________________________________________Ç
WADE S. WILLIAMS and CHRYSTAL PEART,
NOTICE OF MOTION
Plaintiff(s),
-against- Index No: 508561/2021
JOHN DOE, said name being fictitious and unknown,
and EAN HOLDINGS, LLC.,
Defendant(s).
__________________________________________________________________Ç
COUNSELORS:
PLEASE TAKE NOTICE, that upon the annexed Affirmation of BARRY J. UNGAR,
ESQ., dated August 1, 2022, and upon all the pleading and proceedings heretofore had herein, the
undersigned will move this Court at the Courthouse located at 360 Adams Street, Brooklyn, New York,
22nd thereafter
on the day of August, 2022, at 9:30 o'clock in the forenoon of that day or as soon as Counsel
may be heard for an Order: (i) pursuant to CPLR § 3124, compelling plaintiffs to provide all outstanding
documentary discovery listed herein; (ii) compelling plaintiffs to proceed with court ordered depositions
and (iii) granting such other and further relief as to the Court may seem just, proper, and equitable.
PLEASE TAKE FURTHER NOTICE, that pursuant to CPLR § 2214 answering
affidavits, if any, must be served upon movant's counsel at least seven (7) days prior to the return
date of this motion.
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FILED: KINGS COUNTY CLERK 08/01/2022 12:26 PM INDEX NO. 508561/2021
NYSCEF DOC. NO. 74 RECEIVED NYSCEF: 08/01/2022
Dated: Mineola, New York
August 1, 2022
Yours etc.,
RANKIN SAVIDGE, PLLC
BY: BARRY J. UNGAR
Attorneys for Defendant(s)
EAN HOLDINGS, LLC
1527 Franklin Avenue, Suite 100
Mineola, New York 11501
T. (516) 208-1640
F. (646) 736-0958
To:
DAVIDOFF LAW JAMES G. BILELLO & ASSOCIATES
Attorneys for Plaintiffs Attorneys for Plaintiff on the Counterclaim
WADE S. WILLIAMS WADE WILLIAMS
and CHRYSTAL PEAERT 100 Duffy Avenue, STE 500
108-18 Queens Boulevard Hicksville, New York 11801
4th
FlOOr, Suite 404 (516) 861-1781
Forest Hills, New York 11375
Ph: (718) 268-8800
2 of 2
Document Filed Date
August 01, 2022
Case Filing Date
April 12, 2021
Category
Torts - Motor Vehicle
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Preview
FILED: KINGS COUNTY CLERK 08/01/2022 12:26 PM INDEX NO. 508561/2021 NYSCEF DOC. NO. 74 RECEIVED NYSCEF: 08/01/2022 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF KINGS _________________________________________________________________Ç WADE S. WILLIAMS and CHRYSTAL PEART, NOTICE OF MOTION Plaintiff(s), -against- Index No: 508561/2021 JOHN DOE, said name being fictitious and unknown, and EAN HOLDINGS, LLC., Defendant(s). __________________________________________________________________Ç COUNSELORS: PLEASE TAKE NOTICE, that upon the annexed Affirmation of BARRY J. UNGAR, ESQ., dated August 1, 2022, and upon all the pleading and proceedings heretofore had herein, the undersigned will move this Court at the Courthouse located at 360 Adams Street, Brooklyn, New York, 22nd thereafter on the day of August, 2022, at 9:30 o'clock in the forenoon of that day or as soon as Counsel may be heard for an Order: (i) pursuant to CPLR § 3124, compelling plaintiffs to provide all outstanding documentary discovery listed herein; (ii) compelling plaintiffs to proceed with court ordered depositions and (iii) granting such other and further relief as to the Court may seem just, proper, and equitable. PLEASE TAKE FURTHER NOTICE, that pursuant to CPLR § 2214 answering affidavits, if any, must be served upon movant's counsel at least seven (7) days prior to the return date of this motion. 1 of 2 FILED: KINGS COUNTY CLERK 08/01/2022 12:26 PM INDEX NO. 508561/2021 NYSCEF DOC. NO. 74 RECEIVED NYSCEF: 08/01/2022 Dated: Mineola, New York August 1, 2022 Yours etc., RANKIN SAVIDGE, PLLC BY: BARRY J. UNGAR Attorneys for Defendant(s) EAN HOLDINGS, LLC 1527 Franklin Avenue, Suite 100 Mineola, New York 11501 T. (516) 208-1640 F. (646) 736-0958 To: DAVIDOFF LAW JAMES G. BILELLO & ASSOCIATES Attorneys for Plaintiffs Attorneys for Plaintiff on the Counterclaim WADE S. WILLIAMS WADE WILLIAMS and CHRYSTAL PEAERT 100 Duffy Avenue, STE 500 108-18 Queens Boulevard Hicksville, New York 11801 4th FlOOr, Suite 404 (516) 861-1781 Forest Hills, New York 11375 Ph: (718) 268-8800 2 of 2