On May 23, 2017 a
Motion,Ex Parte
was filed
involving a dispute between
Bankers Standard Insurance Company As Subrogee Of Russell Umphenour And Debra London,
and
Nj Paz Painting Services, Inc.,
North Moore Nyc Property, Inc.,
for Commercial - Contract
in the District Court of New York County.
Preview
FILED: NEW YORK COUNTY CLERK 08/28/2018 03:55 PM INDEX NO. 652792/2017
NYSCEF DOC. NO. 4 RECEIVED NYSCEF: 08/28/2018
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF NEW YORK
-----------------------------------------------------------------X
BANKERS STANDARD INSURANCE COMPANY
as subrogee ofRUSSELL UMPHENOUR and
Index No.: 652792/2017
DEBRA LONDON,
Plaintiff,
NOTICE OF MOTION TO
v. EXTEND TIME TO SERVE
SUPPLEMENTAL SUMMONS
NORTH MOORE NYC PROPERTY, INC., AND AND AMENDED COMPLAINT
NJ PAZ PAINTING SERVICES, INC.,
Defendants.
----------------------------------------- ---------------X
PLEASE TAKE NOTICE, that upon the annexed Affirmation of Robert A. Stern, Esq.,
and the exhibits annexed hereto, BANKERS STANDARD INSURANCE COMPANY as
subrogee ofRUSSELL UMPHENOUR and DEBRA LONDON, (hereinafter "Plaintiff"), by and
through its attorneys, Clausen Miller P.C., will move this Court at the Courthouse, located at 60
Centre Street, Room 130, New York, New York, 10007, on September 5, 2018, at 9:30 o'clock
in the forenoon of that day, or as soon thereafter as counsel can be heard, for an Order:
(a) Pursuant to CPLR § 306-b, granting Plaintiff an Order Extending the Time to Serve
Defendant NJ Paz Painting Services, Inc., by 120 days from the date of entry of an Order
deciding this Motion;
(b) Granting Plaintiff such other, further and different relief as this Honorable Court
may deem just, proper and equitable.
PLEASE TAKE FURTHER NOTICE that pursuant to CPLR § 2214 (b), demand is
hereby made that answering Affidavits and/or Memorandum of Law, ifany, shall be served on
the undersigned at least two (2) days prior to the date at which time this Motion has been noticed
to be heard.
Dated: New York, New York
August 28, 2018
459032.1
1 of 2
FILED: NEW YORK COUNTY CLERK 08/28/2018 03:55 PM INDEX NO. 652792/2017
NYSCEF DOC. NO. 4 RECEIVED NYSCEF: 08/28/2018
CLAUSEN MILLER P.C.
By:
Robert A. Stern, Esq.
Attorneys for Plaintiff
-39th
28 Liberty Street PlOOr
New York, New York 10005
(212) 805-3900
TO:
NORTH MOORE NYC PROPERTY, INC.
c/o PAVIA & HARCOURT LLP
230 PARK AVENUE, SUITE 2401
NEW YORK, NY 10169
459032.1
2 of 2
Document Filed Date
August 28, 2018
Case Filing Date
May 23, 2017
Category
Commercial - Contract
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Preview
FILED: NEW YORK COUNTY CLERK 08/28/2018 03:55 PM INDEX NO. 652792/2017 NYSCEF DOC. NO. 4 RECEIVED NYSCEF: 08/28/2018 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF NEW YORK -----------------------------------------------------------------X BANKERS STANDARD INSURANCE COMPANY as subrogee ofRUSSELL UMPHENOUR and Index No.: 652792/2017 DEBRA LONDON, Plaintiff, NOTICE OF MOTION TO v. EXTEND TIME TO SERVE SUPPLEMENTAL SUMMONS NORTH MOORE NYC PROPERTY, INC., AND AND AMENDED COMPLAINT NJ PAZ PAINTING SERVICES, INC., Defendants. ----------------------------------------- ---------------X PLEASE TAKE NOTICE, that upon the annexed Affirmation of Robert A. Stern, Esq., and the exhibits annexed hereto, BANKERS STANDARD INSURANCE COMPANY as subrogee ofRUSSELL UMPHENOUR and DEBRA LONDON, (hereinafter "Plaintiff"), by and through its attorneys, Clausen Miller P.C., will move this Court at the Courthouse, located at 60 Centre Street, Room 130, New York, New York, 10007, on September 5, 2018, at 9:30 o'clock in the forenoon of that day, or as soon thereafter as counsel can be heard, for an Order: (a) Pursuant to CPLR § 306-b, granting Plaintiff an Order Extending the Time to Serve Defendant NJ Paz Painting Services, Inc., by 120 days from the date of entry of an Order deciding this Motion; (b) Granting Plaintiff such other, further and different relief as this Honorable Court may deem just, proper and equitable. PLEASE TAKE FURTHER NOTICE that pursuant to CPLR § 2214 (b), demand is hereby made that answering Affidavits and/or Memorandum of Law, ifany, shall be served on the undersigned at least two (2) days prior to the date at which time this Motion has been noticed to be heard. Dated: New York, New York August 28, 2018 459032.1 1 of 2 FILED: NEW YORK COUNTY CLERK 08/28/2018 03:55 PM INDEX NO. 652792/2017 NYSCEF DOC. NO. 4 RECEIVED NYSCEF: 08/28/2018 CLAUSEN MILLER P.C. By: Robert A. Stern, Esq. Attorneys for Plaintiff -39th 28 Liberty Street PlOOr New York, New York 10005 (212) 805-3900 TO: NORTH MOORE NYC PROPERTY, INC. c/o PAVIA & HARCOURT LLP 230 PARK AVENUE, SUITE 2401 NEW YORK, NY 10169 459032.1 2 of 2