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  • Kenneth L. Mitchell v. Glen P. Miller Torts - Motor Vehicle document preview
  • Kenneth L. Mitchell v. Glen P. Miller Torts - Motor Vehicle document preview
  • Kenneth L. Mitchell v. Glen P. Miller Torts - Motor Vehicle document preview
  • Kenneth L. Mitchell v. Glen P. Miller Torts - Motor Vehicle document preview
						
                                

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FILED: KINGS COUNTY CLERK 05/18/2021 03:23 PM INDEX NO. 527995/2019 NYSCEF DOC. NO. 15 RECEIVED NYSCEF: 05/18/2021 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF KINGS KENNETH L. MITCHELL, Index No. 527995/2019 Plaintiff, NOTICE OF MOTION -against- FOR PARTIAL SUMMARY JUDGMENT ON THE GLEN P. MILLER, ISSUE OF LIABILITY Defendant. C O U N S E L O R S : PLEASE TAKE NOTICE, that upon the annexed affidavit of KENNETH L. MITCHELL, sworn to on May 18, 2021, the affirmation of Mila N. Andreou, dated May 18, 2021, and upon all the pleadings and proceedings heretofore had herein, the undersigned will move 401 before this Court at the Courthouse located at 360 Adams Street, Brooklyn, New York on the day of June, 2021, at 9:30 am in the forenoon of that day or as soon thereafter as counsel can be heard: For an order pursuant to Section 3212 of the Civil Practice Law and Rules granting partial summary judgment on the issue of liability in favor of the plaintiff and against the defendant GLEN P. MILLER, dismissing defendant's first affirmative defense that the plaintiff was comparatively at fault, and for such other and further relief as to this Court may seem just and proper. The above-entitled action is for personal injuries. This action is not on the trial calendar. TAKE FURTHER NOTICE that, pursuant to Section 2214(b) of the Civil Practice Law and Rules, all answering papers, if any, shall be served at least seven (7) days before the return date of this motion. Dated: Rockville Centre, NY May 18, 2021 By: Mila N. Andreou, Esq. GABRIEL LAW FIRM, P.C. 1 of 2 FILED: KINGS COUNTY CLERK 05/18/2021 03:23 PM INDEX NO. 527995/2019 NYSCEF DOC. NO. 15 RECEIVED NYSCEF: 05/18/2021 Attorneys for Plaintiff 2 Lincoln Ave. Suite 400 Rockville Centre, NY 11570 (516)360-9101 TO: Douglas Piacentini, Esq. James G. Bilello & Associates Attorney for Defendant 100 Duffy Avenue, Suite 500 Hicksville, NY 11801 (516) 861-1804 2 of 2