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  • Christian Russell v. Houslanger & Associates, Pllc, Todd E Houslanger Other Matters - Consumer Credit (Non-Card) Transaction document preview
						
                                

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FILED: NEW YORK COUNTY CLERK 10/25/2017 12:23 AM INDEX NO. 154967/2017 NYSCEF DOC. NO. 4 RECEIVED NYSCEF: 10/25/2017 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF NEW YORK -----------------------------------------------------------------------X CHRISTIAN RUSSELL, INDEX NO.: 154967/2017 Plaintiff, NOTICE OF MOTION TO DISMISS -against- HOUSLANGER & ASSOCIATES, PLLC, Return Date: 11/14/2017 AND TODD E. HOUSLANGER, Defendants. -------------------------------------------------------------------------X PLEASE TAKE NOTICE, that upon the annexed Affirmation of Todd E. Houslanger, Esq., dated October 25, 2017, the summons, and the demand for a complaint heretofore served herein, a motion pursuant to CPLR § 3012(b) will be made at the Supreme Court of the State of New York, County of New York, located at 60 Centre Street, New York, NY 10007 at an IAS Term, on the 14th day of November, 2017 at 9:30 AM, or as soon thereafter as counsel can be heard, for an order dismissing the above-entitled action upon the ground that Plaintiff has failed to serve the complaint within twenty (20) days after service of a demand therefor, and/or in the alternative, dismissing the action against defendants Todd E. Houslanger and Houslanger & Associates, PLLC, pursuant to CPLR § 3211(a)(1) and/or 3211(a)(2) and/or 3211(a)(7) and/or 3211(a)(8) and for such other and further relief as this Court may deem to be just, proper and equitable. PLEASE TAKE FURTHER NOTICE, that Pursuant to CPLR §2214(b), answering affidavits, if any, are required to be served upon the undersigned at least seven days (7) before the return date. Dated: October 25, 2017 Huntington, New York ______________________________________ Todd E. Houslanger, Esq. HOUSLANGER & ASSOCIATES, PLLC Attorney for Defendants HOUSLANGER & ASSOCIATES, PLLC and TODD E. HOUSLANGER 372 New York Avenue TO: Mitchell L. Pashkin, Esq. Huntington, New York 11743 775 Park Avenue, Suite 255 (631) 427-1140 Huntington, NY 11743 Our File No.: 299327 1 of 1