On July 24, 2019 a
Motion,Ex Parte
was filed
involving a dispute between
Dario Rosario,
and
Brooklyn Gc Llc,
Perez Javier,
Quality Facility Solutions Corp.,
Sunbelt Rentals, Inc.,
for Torts - Motor Vehicle
in the District Court of Kings County.
Preview
FILED: KINGS COUNTY CLERK 03/19/2021 11:09 AM INDEX NO. 516285/2019
NYSCEF DOC. NO. 65 RECEIVED NYSCEF: 03/19/2021
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF KINGS Index No.: 516285/2019
=============================================X
DARIO ROSARIO,
NOTICE OF MOTION
Plaintiff,
-against-
SUNBELT RENTALS, INC., PEREZ JAVIER, BROOKLYN
GC LLC and QUALITY FACILITY SOLUTIONS CORP.,
Defendants.
=============================================X
MOTION BY: LIAKAS LAW, P.C., attorneys for Plaintiff, DARIO
ROSARIO.
DATE, TIME AND PLACE: On the 14th day of May, 2021 at 9:30 o’clock in the forenoon
of that day or as soon thereafter as counsel can be heard at
IAS Part of the courthouse located at 360 Adams Street,
Brooklyn, New York 11201.
SUPPORTING PAPERS: Affirmation of Stephen J. Liakas ESQ., dated March 19,
2021, the exhibits hereto attached and upon all the pleadings
and proceedings heretofore had herein.
RELIEF DEMANDED: For an order: 1) granting Plaintiff, DARIO ROSARIO,
summary judgment on the issue of liability, pursuant to
CPLR §3212; 2) striking Defendants affirmative defenses of
negligence, culpable conduct, comparative negligence,
contributory negligence and/or assumption of risk as Plaintiff
did not cause or contribute to the happening of the subject
accident, and; ) for such other and further relief as the Court
deems necessary and proper.
1 of 2
FILED: KINGS COUNTY CLERK 03/19/2021 11:09 AM INDEX NO. 516285/2019
NYSCEF DOC. NO. 65 RECEIVED NYSCEF: 03/19/2021
ANSWERING AFFIDAVITS: Pursuant to Rule 2214(b) answering affidavits are to be
served upon the undersigned at least seven (7) days prior to
the return date hereof.
Dated: New York, New York
March 19, 2021
LIAKAS LAW, P.C.
/s/ Stephen J. Liakas
Stephen J. Liakas, ESQ.
Attorneys for Plaintiff
65 Broadway, 13th Floor
New York, New York 10006
212-937-7765
To: MOLOD SPITZ & DESANTIS, P.C.
Attorneys for Defendant
QUALITY FACILITY SOLUTIONS CORP. and PEREZ JAVIER
1430 Broadway, 21st Floor
New York, New York 10018
212-869-3200
ALLYN & FORTUNA LLP
Attorneys for Defendant
BROOKLYN GC, LLC
1010 Avenue of the Americas, 3rd Floor
New York, New York 10018
SCHNADER HARRISON SEGAL & LEWIS LLP
Attorneys for Defendant
SUNBELT RENTALS, INC.
140 Broadway, Suite 3100
New York, New York 10005
212-973-8000
2 of 2
Document Filed Date
March 19, 2021
Case Filing Date
July 24, 2019
Category
Torts - Motor Vehicle
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Preview
FILED: KINGS COUNTY CLERK 03/19/2021 11:09 AM INDEX NO. 516285/2019 NYSCEF DOC. NO. 65 RECEIVED NYSCEF: 03/19/2021 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF KINGS Index No.: 516285/2019 =============================================X DARIO ROSARIO, NOTICE OF MOTION Plaintiff, -against- SUNBELT RENTALS, INC., PEREZ JAVIER, BROOKLYN GC LLC and QUALITY FACILITY SOLUTIONS CORP., Defendants. =============================================X MOTION BY: LIAKAS LAW, P.C., attorneys for Plaintiff, DARIO ROSARIO. DATE, TIME AND PLACE: On the 14th day of May, 2021 at 9:30 o’clock in the forenoon of that day or as soon thereafter as counsel can be heard at IAS Part of the courthouse located at 360 Adams Street, Brooklyn, New York 11201. SUPPORTING PAPERS: Affirmation of Stephen J. Liakas ESQ., dated March 19, 2021, the exhibits hereto attached and upon all the pleadings and proceedings heretofore had herein. RELIEF DEMANDED: For an order: 1) granting Plaintiff, DARIO ROSARIO, summary judgment on the issue of liability, pursuant to CPLR §3212; 2) striking Defendants affirmative defenses of negligence, culpable conduct, comparative negligence, contributory negligence and/or assumption of risk as Plaintiff did not cause or contribute to the happening of the subject accident, and; ) for such other and further relief as the Court deems necessary and proper. 1 of 2 FILED: KINGS COUNTY CLERK 03/19/2021 11:09 AM INDEX NO. 516285/2019 NYSCEF DOC. NO. 65 RECEIVED NYSCEF: 03/19/2021 ANSWERING AFFIDAVITS: Pursuant to Rule 2214(b) answering affidavits are to be served upon the undersigned at least seven (7) days prior to the return date hereof. Dated: New York, New York March 19, 2021 LIAKAS LAW, P.C. /s/ Stephen J. Liakas Stephen J. Liakas, ESQ. Attorneys for Plaintiff 65 Broadway, 13th Floor New York, New York 10006 212-937-7765 To: MOLOD SPITZ & DESANTIS, P.C. Attorneys for Defendant QUALITY FACILITY SOLUTIONS CORP. and PEREZ JAVIER 1430 Broadway, 21st Floor New York, New York 10018 212-869-3200 ALLYN & FORTUNA LLP Attorneys for Defendant BROOKLYN GC, LLC 1010 Avenue of the Americas, 3rd Floor New York, New York 10018 SCHNADER HARRISON SEGAL & LEWIS LLP Attorneys for Defendant SUNBELT RENTALS, INC. 140 Broadway, Suite 3100 New York, New York 10005 212-973-8000 2 of 2