Preview
FILED: NEW YORK COUNTY CLERK 04/05/2022 04:07 PM INDEX NO. 652321/2020
NYSCEF DOC. NO. 49 RECEIVED NYSCEF: 04/05/2022
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF NEW YORK
E.E. CRUZ & COMPANY, INC., Index No.: 652321/2020
Plaintiffs,
NOTICE OF MOTION TO
- against - ADMIT JONATHAN W.
CHAMBERS PRO HAC VICE
STARR SURPLUS LINES INSURANCE
COMPANY
Defendants.
PLEASE TAKE NOTICE that upon the annexed affirmation of Stacy M.
Manobianca, dated April 5, 2022 (the "Manobianca Affirmation"), the exhibits thereto, together
with the Affidavit of Jonathan W. Chambers, Esq., and upon all prior pleadings and proceedings
had herein, Plaintiff will move this Court, at the Motion Support Office in and for the County of
New York, located at 60 Centre Street, Room 130, New York, State of New York, on April 26,
2022 at 9:30 a.m., or as soon thereafter as counsel may be heard, for an Order, pursuant to
N.Y.C.R.R. § 520.11 and 22 N.Y.C.R.R. § 602.2, allowing the pro hac vice admission of Jonathan
W. Chambers, Esq., an attorney at law of Saxe Doernberger & Vita, P.C., located in Trumbull,
Connecticut, to argue or try this case in whole or in part as counsel or advocate on behalf of
Plaintiffs in the above-captioned matter, together with any other and further relief the Court deems
just and proper.
PLEASE TAKE FURTHER NOTICE that, pursuant to CPLR 2214(b), answering
papers, if any, must be served at least seven (7) days before the return date of this motion.
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FILED: NEW YORK COUNTY CLERK 04/05/2022 04:07 PM INDEX NO. 652321/2020
NYSCEF DOC. NO. 49 RECEIVED NYSCEF: 04/05/2022
Please take further notice that oral argument is respectfully requested if the
motion is opposed.
Dated: Trumbull, Connecticut
April 5, 2022
SAXE DOERNBER & VITA, P.C.
By: _________________________________
Stacy M. Manobianca (NY Bar: 4395935)
35 Nutmeg Drive
Suite 140
Trumbull, CT 06611
smanobianca@sdvlaw.com
203-287-2100
Attorneys for plaintiff
TO:
Charles J. Rocco
crocco@fgppr.com
Ashley C. Vicere
avicere@fgppr.com
Foran Glennon Palandech Ponzi & Rudloff, P.C.
40 Wall Street
New York, New York 10005
Tel: (212) 257-7100
Attorney for Defendants
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FILED: NEW YORK COUNTY CLERK 04/05/2022 04:07 PM INDEX NO. 652321/2020
NYSCEF DOC. NO. 49 RECEIVED NYSCEF: 04/05/2022
ATTORNEYS AFFIRMATION OF SERVICE
STACY M. MANOBIANCA, an attorney duly admitted to practice law before the Courts
of the State of New York and an attorney with the law firm of Saxe Doernberger & Vita, P.C.,
attorneys for Plaintiff, E.E. Cruz & Company Inc., affirms the following to be true, under the
penalty of perjury:
That on 5th day of April, 2022, I served the annexed Notice of Motion for Pro Hac Vice
Admission, Affirmation of Stacy Manobianca, Esq., Affidavit of Jonathan W. Chambers , Esq.
and this Affirmation of Service, along with all supporting documentation, via electronic filing with
the New York Supreme Court, New York County, causing same to be served upon the following:
Charles J. Rocco
crocco@fgppr.com
Ashley C. Vicere
avicere@fgppr.com
Foran Glennon Palandech Ponzi & Rudloff, P.C.
40 Wall Street
New York, New York 10005
Tel: (212) 257-7100
Attorney for Defendants
Dated: Trumbull, Connecticut
April 5, 2021
___________________________________
Stacy M. Manobianca (NY Bar: 4395935)
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Preview
FILED: NEW YORK COUNTY CLERK 04/05/2022 04:07 PM INDEX NO. 652321/2020 NYSCEF DOC. NO. 49 RECEIVED NYSCEF: 04/05/2022 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF NEW YORK E.E. CRUZ & COMPANY, INC., Index No.: 652321/2020 Plaintiffs, NOTICE OF MOTION TO - against - ADMIT JONATHAN W. CHAMBERS PRO HAC VICE STARR SURPLUS LINES INSURANCE COMPANY Defendants. PLEASE TAKE NOTICE that upon the annexed affirmation of Stacy M. Manobianca, dated April 5, 2022 (the "Manobianca Affirmation"), the exhibits thereto, together with the Affidavit of Jonathan W. Chambers, Esq., and upon all prior pleadings and proceedings had herein, Plaintiff will move this Court, at the Motion Support Office in and for the County of New York, located at 60 Centre Street, Room 130, New York, State of New York, on April 26, 2022 at 9:30 a.m., or as soon thereafter as counsel may be heard, for an Order, pursuant to N.Y.C.R.R. § 520.11 and 22 N.Y.C.R.R. § 602.2, allowing the pro hac vice admission of Jonathan W. Chambers, Esq., an attorney at law of Saxe Doernberger & Vita, P.C., located in Trumbull, Connecticut, to argue or try this case in whole or in part as counsel or advocate on behalf of Plaintiffs in the above-captioned matter, together with any other and further relief the Court deems just and proper. PLEASE TAKE FURTHER NOTICE that, pursuant to CPLR 2214(b), answering papers, if any, must be served at least seven (7) days before the return date of this motion. 1 1 of 3 FILED: NEW YORK COUNTY CLERK 04/05/2022 04:07 PM INDEX NO. 652321/2020 NYSCEF DOC. NO. 49 RECEIVED NYSCEF: 04/05/2022 Please take further notice that oral argument is respectfully requested if the motion is opposed. Dated: Trumbull, Connecticut April 5, 2022 SAXE DOERNBER & VITA, P.C. By: _________________________________ Stacy M. Manobianca (NY Bar: 4395935) 35 Nutmeg Drive Suite 140 Trumbull, CT 06611 smanobianca@sdvlaw.com 203-287-2100 Attorneys for plaintiff TO: Charles J. Rocco crocco@fgppr.com Ashley C. Vicere avicere@fgppr.com Foran Glennon Palandech Ponzi & Rudloff, P.C. 40 Wall Street New York, New York 10005 Tel: (212) 257-7100 Attorney for Defendants 2 2 of 3 FILED: NEW YORK COUNTY CLERK 04/05/2022 04:07 PM INDEX NO. 652321/2020 NYSCEF DOC. NO. 49 RECEIVED NYSCEF: 04/05/2022 ATTORNEYS AFFIRMATION OF SERVICE STACY M. MANOBIANCA, an attorney duly admitted to practice law before the Courts of the State of New York and an attorney with the law firm of Saxe Doernberger & Vita, P.C., attorneys for Plaintiff, E.E. Cruz & Company Inc., affirms the following to be true, under the penalty of perjury: That on 5th day of April, 2022, I served the annexed Notice of Motion for Pro Hac Vice Admission, Affirmation of Stacy Manobianca, Esq., Affidavit of Jonathan W. Chambers , Esq. and this Affirmation of Service, along with all supporting documentation, via electronic filing with the New York Supreme Court, New York County, causing same to be served upon the following: Charles J. Rocco crocco@fgppr.com Ashley C. Vicere avicere@fgppr.com Foran Glennon Palandech Ponzi & Rudloff, P.C. 40 Wall Street New York, New York 10005 Tel: (212) 257-7100 Attorney for Defendants Dated: Trumbull, Connecticut April 5, 2021 ___________________________________ Stacy M. Manobianca (NY Bar: 4395935) 3 3 of 3