On May 27, 2022 a
Motion,Ex Parte
was filed
involving a dispute between
James Moran,
and
Glenn A. Reiner,
Grand Slam Ventures, Llc,
Jg Real Estate Ventures, Llc,
'John Does' 1-10 Inclusive, The Last Ten Names Being Fictitious And Unknown To Plaintiff,
Jon Steinberg,
for Other Matters - Contract - Other
in the District Court of Nassau County.
Preview
FILED: NASSAU COUNTY CLERK 06/23/2022 05:18 PM INDEX NO. 001052/2019
NYSCEF DOC. NO. 17 RECEIVED NYSCEF: 06/23/2022
SUPREME COURT OF THE STATE OF NEW YORK Return Date July 19, 2022
COUNTY OF NASSAU Hon. Erica L. Prager
----------------------------------------------------------------- -----x Index No. 001052/2019
JAMES MORAN,
Plaintiff,
NOTICE OF MOTION
FOR SANCTIONS
-against-
GRAND SLAM VENTURES, LLC, JON STEINBERG,
GLENN A. REINER, JG REAL ESTATE VENTURES,
LLC, and "JOHN DOES" # 1-10 inclusive, the last ten
names being fictitious and unknown to plaintiff,
Defendants.
-----------------------------------------------------------------------x
SIRS/MADAMS:
PLEASE TAKE NOTICE, that upon the annexed affidavit of James Moran, dated June 23,
2022 and the exhibits, annexed thereto by reference, the accompanying Memorandum of Law in
Support and all other papers and proceedings heretofore had herein and hereto filed herein, the
undersigned will move this Court at an IAS Term before the Honorable Erica L. Prager, a Justice
of the Supreme Court, County of Nassau, at the Courthouse located at 100 Supreme Court Drive,
Mineola, New York, 11501 on the 19th day of July 2022, at 9:30 am in the forenoon of that day,
or as soon thereafter as Counsel can be heard, for an Order, a) striking Defendants' Verified
Answer or precluding the Defendants from contesting that Defendant Grand Slam was insolvent
and/or rendered insolvent as a result of the subject conveyance and/or that fair consideration was
given for the conveyance of the subject Property for Defendants' willful spoliation of relevant
evidence; and/or b) pursuant to CPLR §3126, striking Defendants' Verified Answer and/or
precluding Defendants from introducing, on motion and/or at trial, any evidence not produced in
accordance with the Order of this Court dated August 30, 2021; and/or c) for such other, further
and different relief as this Honorable Court may deem just, proper and equitable.
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FILED: NASSAU COUNTY CLERK 06/23/2022 05:18 PM INDEX NO. 001052/2019
NYSCEF DOC. NO. 17 RECEIVED NYSCEF: 06/23/2022
PLEASE TAKE FURTHER NOTICE, that pursuant to CPLR §2214 answering papers, if
any, shall be served upon the undersigned at least seven (7) days before the return date of this
motion.
Dated: June 23, 2022
Bethpage, New York
James Moran
Plaintiff pro se
28 Carrie Avenue
Bethpage, New York 11714
Tel: (516) 302-6581
Email: jim.catlawl@gmail.com
To: Siegel & Reiner, LLP
Attorneys for Defendants
GRAND SLAM VENTURES, LLC,
JON STEINBERG, GLENN A. REINER
and JG REAL ESTATE VENTURES, LLC
130 East 59th Street, 12th Floor
New York, New York 10022
Tel: (212) 447-5599
Email: rdelvalle@siegelreiner.com
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FILED: NASSAU COUNTY CLERK 06/23/2022 05:18 PM INDEX NO. 001052/2019 NYSCEF DOC. NO. 17 RECEIVED NYSCEF: 06/23/2022 SUPREME COURT OF THE STATE OF NEW YORK Return Date July 19, 2022 COUNTY OF NASSAU Hon. Erica L. Prager ----------------------------------------------------------------- -----x Index No. 001052/2019 JAMES MORAN, Plaintiff, NOTICE OF MOTION FOR SANCTIONS -against- GRAND SLAM VENTURES, LLC, JON STEINBERG, GLENN A. REINER, JG REAL ESTATE VENTURES, LLC, and "JOHN DOES" # 1-10 inclusive, the last ten names being fictitious and unknown to plaintiff, Defendants. -----------------------------------------------------------------------x SIRS/MADAMS: PLEASE TAKE NOTICE, that upon the annexed affidavit of James Moran, dated June 23, 2022 and the exhibits, annexed thereto by reference, the accompanying Memorandum of Law in Support and all other papers and proceedings heretofore had herein and hereto filed herein, the undersigned will move this Court at an IAS Term before the Honorable Erica L. Prager, a Justice of the Supreme Court, County of Nassau, at the Courthouse located at 100 Supreme Court Drive, Mineola, New York, 11501 on the 19th day of July 2022, at 9:30 am in the forenoon of that day, or as soon thereafter as Counsel can be heard, for an Order, a) striking Defendants' Verified Answer or precluding the Defendants from contesting that Defendant Grand Slam was insolvent and/or rendered insolvent as a result of the subject conveyance and/or that fair consideration was given for the conveyance of the subject Property for Defendants' willful spoliation of relevant evidence; and/or b) pursuant to CPLR §3126, striking Defendants' Verified Answer and/or precluding Defendants from introducing, on motion and/or at trial, any evidence not produced in accordance with the Order of this Court dated August 30, 2021; and/or c) for such other, further and different relief as this Honorable Court may deem just, proper and equitable. Page 1 of2 1 of 2 FILED: NASSAU COUNTY CLERK 06/23/2022 05:18 PM INDEX NO. 001052/2019 NYSCEF DOC. NO. 17 RECEIVED NYSCEF: 06/23/2022 PLEASE TAKE FURTHER NOTICE, that pursuant to CPLR §2214 answering papers, if any, shall be served upon the undersigned at least seven (7) days before the return date of this motion. Dated: June 23, 2022 Bethpage, New York James Moran Plaintiff pro se 28 Carrie Avenue Bethpage, New York 11714 Tel: (516) 302-6581 Email: jim.catlawl@gmail.com To: Siegel & Reiner, LLP Attorneys for Defendants GRAND SLAM VENTURES, LLC, JON STEINBERG, GLENN A. REINER and JG REAL ESTATE VENTURES, LLC 130 East 59th Street, 12th Floor New York, New York 10022 Tel: (212) 447-5599 Email: rdelvalle@siegelreiner.com Page 2 of2 2 of 2