On October 03, 2018 a
Motion,Ex Parte
was filed
involving a dispute between
Raul Santillan,
and
Mana M. Waiba,
The New World Service Inc.,
for Torts - Motor Vehicle
in the District Court of Kings County.
Preview
FILED: KINGS COUNTY CLERK 07/26/2021 02:47 PM INDEX NO. 519867/2018
NYSCEF DOC. NO. 53 RECEIVED NYSCEF: 07/26/2021
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF KINGS
---------------------------------------------------------------------X
RAUL SANTILLAN,
Plaintiff, NOTICE OF MOTION
FOR SUMMARY
- against - JUDGMENT
THE NEW WORLD SERVICE INC. and Index No. 519867/18
MANA M. WAIBA,
Assigned to: J. Landicino
Defendants.
__ .___________________________--------------X
PLEASE TAKE NOTICE that, upon the annexed affirmation of RONALD W.
26th
RAMIREZ, affirmed the day Of July, 2021, and the exhibits annexed thereto, and upon the
pleadings and proceedings heretofore had herein, the undersigned will move this Court at a
Motion Support Part, at the courthouse located at 360 Adams Street, Brooklyn, New York, o_n_
25th
the day Of August, 2021 at 9:30 o'clock in the forenoon of that day, or as soon thereafter as
counsel can be heard, for an order pursuant to CPLR §3212 granting Plaintiff summary judgment
against Defendants as a matter of law on the issue of liability, and for such other and further
relief that this Court may deem just and proper.
PLEASE TAKE FURTHER NOTICE that, pursuant to CPLR §2214(b), answering
affidavits, if any, are to be served upon the undersigned within seven (7) days prior to the return
date of the within motion.
Dated: Forest Hills, New York
July 26, 2021
You 2 c.,
'
Ro ald W. Ra ez
1 of 3
FILED: KINGS COUNTY CLERK 07/26/2021 02:47 PM INDEX NO. 519867/2018
NYSCEF DOC. NO. 53 RECEIVED NYSCEF: 07/26/2021
LAW OFFICE OF RONALD W. RAMIREZ
Attorneys for Plaintiff
71"
107-19 Avenue
Forest Hills, New York 11375
(718) 261-6161
File No.: 180012
TO: BAKER, McEVOY & MOSKOVITS, P.C.
Attorneys for Defendants
8th
One Metrotech Center,
Brooklyn, NY 11201
Case ID: 97406
File No.: 1027151
2
2 of 3
FILED: KINGS COUNTY CLERK 07/26/2021 02:47 PM INDEX NO. 519867/2018
NYSCEF DOC. NO. 53 RECEIVED NYSCEF: 07/26/2021
Index No. 519867/18 (J. Landicino)
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF KINGS
RAUL SANTILLAN,
Plaintiff,
- against -
THE NEW WORLD SERVICE INC. and MANA M. WAIBA,
Defendants.
NOTICE OF MOTION FOR SUMMARY JUDGMENT and
AFFIRMATION IN SUPPORT OF MOTION FOR SUMMARY JUDGMENT
-- .-
LAW OFFICE OF RONALD W. RAMIREZ
Attorneys for Plaintiff
107-19 71st Avenue
Forest Hills, New York 11375
Tel. No.: (718) 261-6161
Fax No.: (718) 268-3045
RR @ RWRAMIREZ.COM
CERT1FICATION:
To the best of the undersigned's knowledge, informatian and belief, formed after an inquiry
reasonable under the circumstances, the within document(s) and contentions cestaise-3
therein are not frive:6üs as defined in 22 NYCRR §l30-1.1-a.
Dated: Forest Hills, New York
July 26, 2021
R ALD W. EZ
3 of 3
Document Filed Date
July 26, 2021
Case Filing Date
October 03, 2018
Category
Torts - Motor Vehicle
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FILED: KINGS COUNTY CLERK 07/26/2021 02:47 PM INDEX NO. 519867/2018 NYSCEF DOC. NO. 53 RECEIVED NYSCEF: 07/26/2021 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF KINGS ---------------------------------------------------------------------X RAUL SANTILLAN, Plaintiff, NOTICE OF MOTION FOR SUMMARY - against - JUDGMENT THE NEW WORLD SERVICE INC. and Index No. 519867/18 MANA M. WAIBA, Assigned to: J. Landicino Defendants. __ .___________________________--------------X PLEASE TAKE NOTICE that, upon the annexed affirmation of RONALD W. 26th RAMIREZ, affirmed the day Of July, 2021, and the exhibits annexed thereto, and upon the pleadings and proceedings heretofore had herein, the undersigned will move this Court at a Motion Support Part, at the courthouse located at 360 Adams Street, Brooklyn, New York, o_n_ 25th the day Of August, 2021 at 9:30 o'clock in the forenoon of that day, or as soon thereafter as counsel can be heard, for an order pursuant to CPLR §3212 granting Plaintiff summary judgment against Defendants as a matter of law on the issue of liability, and for such other and further relief that this Court may deem just and proper. PLEASE TAKE FURTHER NOTICE that, pursuant to CPLR §2214(b), answering affidavits, if any, are to be served upon the undersigned within seven (7) days prior to the return date of the within motion. Dated: Forest Hills, New York July 26, 2021 You 2 c., ' Ro ald W. Ra ez 1 of 3 FILED: KINGS COUNTY CLERK 07/26/2021 02:47 PM INDEX NO. 519867/2018 NYSCEF DOC. NO. 53 RECEIVED NYSCEF: 07/26/2021 LAW OFFICE OF RONALD W. RAMIREZ Attorneys for Plaintiff 71" 107-19 Avenue Forest Hills, New York 11375 (718) 261-6161 File No.: 180012 TO: BAKER, McEVOY & MOSKOVITS, P.C. Attorneys for Defendants 8th One Metrotech Center, Brooklyn, NY 11201 Case ID: 97406 File No.: 1027151 2 2 of 3 FILED: KINGS COUNTY CLERK 07/26/2021 02:47 PM INDEX NO. 519867/2018 NYSCEF DOC. NO. 53 RECEIVED NYSCEF: 07/26/2021 Index No. 519867/18 (J. Landicino) SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF KINGS RAUL SANTILLAN, Plaintiff, - against - THE NEW WORLD SERVICE INC. and MANA M. WAIBA, Defendants. NOTICE OF MOTION FOR SUMMARY JUDGMENT and AFFIRMATION IN SUPPORT OF MOTION FOR SUMMARY JUDGMENT -- .- LAW OFFICE OF RONALD W. RAMIREZ Attorneys for Plaintiff 107-19 71st Avenue Forest Hills, New York 11375 Tel. No.: (718) 261-6161 Fax No.: (718) 268-3045 RR @ RWRAMIREZ.COM CERT1FICATION: To the best of the undersigned's knowledge, informatian and belief, formed after an inquiry reasonable under the circumstances, the within document(s) and contentions cestaise-3 therein are not frive:6üs as defined in 22 NYCRR §l30-1.1-a. Dated: Forest Hills, New York July 26, 2021 R ALD W. EZ 3 of 3