Preview
FILED: NEW YORK COUNTY CLERK 05/06/2020 09:59 AM INDEX NO. 154212/2017
NYSCEF DOC. NO. 66 RECEIVED NYSCEF: 05/06/2020
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF NEW YORK
-------------- ¬------ ¬-----------------X
JAMEL VARGAS, Index No.: 154212/17
Plaintiff
-against- NOTICE OF MOTION
EAN HOLDING, LLC, CLAUDIA CRISTAL CINTRON,
and LANETTE WOODDARD,
Defendants.
---------------- X
MOTION BY: SCAHILL LAW GROUP, P.C.
Attorneys for Defendant
LANETTE WOODDARD
RETURN DATE, TIME & PLACE: July 23, 2020, Motion
Submissions Part, Room 130,
located at 60 Centre St, New York,
New York, at 9:30 a.m.
SUPPORTING PAPERS: Affirmation of Eric C. Flores and
Exhibits thereto.
RELIEF REQUESTED: An Order (1) pursuant to CPLR
§3126, precluding co-defendants,
EAN HOLDING, L.L.C. and
CLAUDIA CRISTAL CINTRON, from
of fering evidence at the time of
trial due to failure appear for a
deposition, (2) together with such
other and further relief as this
Court deems just and proper.
ANSWERING AFFIDAVITS: Must be served at least 7 days
prior to the return date of this
motion, pursuant to CPLR
§2214(b).
CERTIFICATION: Pursuant to 22 NYCRR 130-1.1, it
is hereby certified that to the best
1 of 4
FILED: NEW YORK COUNTY CLERK 05/06/2020 09:59 AM INDEX NO. 154212/2017
NYSCEF DOC. NO. 66 RECEIVED NYSCEF: 05/06/2020
of the undersigned's knowledge,
information and belief formed
after an inquiry reasonable under
the circumstances, the
presentation of the annexed
papers or contentions therein are
not frivolous as defined by 22
NYCRR 1.1 (c).
Dated: Bethpage, New York
April 21, 2020
Yours, etc.,
ERIC C. FLORES
Attorneys for Defendant
LANETTE WOODDARD
1065 Stewart Avenue, Suite 210
Bethpage, New York 11714
(516) 294-5200
TO: TIKHOMIROV & ASSOC, PLLC.
Attorneys for Plaintiff
1400 Avenue Z, Suite 505
Brooklyn, New York 11235
(718) 676-9100
CARMEN, CALLAHAN & INGHAM, L.L.P.
Attorneys for Defendants
EAN Holdings, L.L.C. and Claudia Cristal Cintron
266 Main Street
Farmingdale, New York 11735
(516) 249-3450
2 of 4
FILED: NEW YORK COUNTY CLERK 05/06/2020 09:59 AM INDEX NO. 154212/2017
NYSCEF DOC. NO. 66 RECEIVED NYSCEF: 05/06/2020
STATE OF NEW YORK, COUNTY OF NASSAU
I, SAMANTHA CRECCO, being sworn, depose and say: I am not a party to the
22nd
action, am over 18 years of age and reside at Nassau County, New York. On the day
of April 2020, I served the within: NOTICE OF MOTION, AFFIRMATION IN
SUPPORT, AFFIRMATION OF GOOD FAITH, and EXHIBITS
TO: TIKHOMIROV & ASSOC, PLLC.
1400 Avenue Z, Suite 505
Brooklyn, New York 11235
CARMEN, CALLAHAN & INGHAM, L.L.P.
266 Main Street
Farmingdale, New York 11735
by depositing a true copy thereof enclosed in a post-paid wrapper, in an official depository
under the exclusive care and custody of the U.S. Postal Service within New York State,
addressed to each of the above at the last known address as set forth after each name.
SAMANTHA CRECCO
Sworn to before me on this
22nd
y of April, 2020.
NOTARY PUT3I(fC
FItANCES D. ANGLERO
Notary Public, State of New York
No. 01ÁN5089279 Suffolk County
Commission Expires December 8,
20_
3 of 4
FILED: NEW YORK COUNTY CLERK 05/06/2020 09:59 AM INDEX NO. 154212/2017
NYSCEF DOC. NO. 66 RECEIVED NYSCEF: 05/06/2020
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF NEW YORK
Index No. 154212/17
JAMEL VARGAS,
Plaintiff,
-against-
EAN HOLDING , LLC, CLAUDIA CRISTAL CINTRON and LANETTE WOODARD,
Defendants.
NOTICE OF MOTION, AFFIRMATION IN SUPPORT, AFFIRMATION OF GOOD
FAITH, and EXHIBITS
SCAHILL LAW GROUP, P.C.
Attorneys for Defendants
LANETFE WOODDARD s/h/aLANETTE WOODARD
1065 Stewart Avenue, Suite210
Bethpage, New York 11714
(516)294-5200
ATTORNEY CERTIFICATION
Pursuant to 22 NYCRR §130-1.1, the undersigned, an attorney admitted to practice in the courts of New
York State, certifiesthat upon information and belief and responsible inquiry, the contentions contained
in the annexed documents are not frivolous.
Dated: April 22, 2020
ERIC C. FLORES
Please take notice
O Notice of entry
that the within is a ( certified) true copy of a duly entered in the office of the clerk of the
within named court on
Oblotice of Settlement;
^
that an order of which the within is a true copy will be presented for settlement to the
HON. one of the judges of the within named court, at on
Dated: Bethpage, New York
Yours, etc.
SCAHILL LAW GROUP, P.C.
Attorneys for Defendants
LANETTE WOODDARD s/h/aLANETTE WOODARD
1065 Stewart Avenue, Suite 210
Bethpage, New York 11714
(516) 294-5200
4 of 4
Preview
FILED: NEW YORK COUNTY CLERK 05/06/2020 09:59 AM INDEX NO. 154212/2017 NYSCEF DOC. NO. 66 RECEIVED NYSCEF: 05/06/2020 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF NEW YORK -------------- ¬------ ¬-----------------X JAMEL VARGAS, Index No.: 154212/17 Plaintiff -against- NOTICE OF MOTION EAN HOLDING, LLC, CLAUDIA CRISTAL CINTRON, and LANETTE WOODDARD, Defendants. ---------------- X MOTION BY: SCAHILL LAW GROUP, P.C. Attorneys for Defendant LANETTE WOODDARD RETURN DATE, TIME & PLACE: July 23, 2020, Motion Submissions Part, Room 130, located at 60 Centre St, New York, New York, at 9:30 a.m. SUPPORTING PAPERS: Affirmation of Eric C. Flores and Exhibits thereto. RELIEF REQUESTED: An Order (1) pursuant to CPLR §3126, precluding co-defendants, EAN HOLDING, L.L.C. and CLAUDIA CRISTAL CINTRON, from of fering evidence at the time of trial due to failure appear for a deposition, (2) together with such other and further relief as this Court deems just and proper. ANSWERING AFFIDAVITS: Must be served at least 7 days prior to the return date of this motion, pursuant to CPLR §2214(b). CERTIFICATION: Pursuant to 22 NYCRR 130-1.1, it is hereby certified that to the best 1 of 4 FILED: NEW YORK COUNTY CLERK 05/06/2020 09:59 AM INDEX NO. 154212/2017 NYSCEF DOC. NO. 66 RECEIVED NYSCEF: 05/06/2020 of the undersigned's knowledge, information and belief formed after an inquiry reasonable under the circumstances, the presentation of the annexed papers or contentions therein are not frivolous as defined by 22 NYCRR 1.1 (c). Dated: Bethpage, New York April 21, 2020 Yours, etc., ERIC C. FLORES Attorneys for Defendant LANETTE WOODDARD 1065 Stewart Avenue, Suite 210 Bethpage, New York 11714 (516) 294-5200 TO: TIKHOMIROV & ASSOC, PLLC. Attorneys for Plaintiff 1400 Avenue Z, Suite 505 Brooklyn, New York 11235 (718) 676-9100 CARMEN, CALLAHAN & INGHAM, L.L.P. Attorneys for Defendants EAN Holdings, L.L.C. and Claudia Cristal Cintron 266 Main Street Farmingdale, New York 11735 (516) 249-3450 2 of 4 FILED: NEW YORK COUNTY CLERK 05/06/2020 09:59 AM INDEX NO. 154212/2017 NYSCEF DOC. NO. 66 RECEIVED NYSCEF: 05/06/2020 STATE OF NEW YORK, COUNTY OF NASSAU I, SAMANTHA CRECCO, being sworn, depose and say: I am not a party to the 22nd action, am over 18 years of age and reside at Nassau County, New York. On the day of April 2020, I served the within: NOTICE OF MOTION, AFFIRMATION IN SUPPORT, AFFIRMATION OF GOOD FAITH, and EXHIBITS TO: TIKHOMIROV & ASSOC, PLLC. 1400 Avenue Z, Suite 505 Brooklyn, New York 11235 CARMEN, CALLAHAN & INGHAM, L.L.P. 266 Main Street Farmingdale, New York 11735 by depositing a true copy thereof enclosed in a post-paid wrapper, in an official depository under the exclusive care and custody of the U.S. Postal Service within New York State, addressed to each of the above at the last known address as set forth after each name. SAMANTHA CRECCO Sworn to before me on this 22nd y of April, 2020. NOTARY PUT3I(fC FItANCES D. ANGLERO Notary Public, State of New York No. 01ÁN5089279 Suffolk County Commission Expires December 8, 20_ 3 of 4 FILED: NEW YORK COUNTY CLERK 05/06/2020 09:59 AM INDEX NO. 154212/2017 NYSCEF DOC. NO. 66 RECEIVED NYSCEF: 05/06/2020 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF NEW YORK Index No. 154212/17 JAMEL VARGAS, Plaintiff, -against- EAN HOLDING , LLC, CLAUDIA CRISTAL CINTRON and LANETTE WOODARD, Defendants. NOTICE OF MOTION, AFFIRMATION IN SUPPORT, AFFIRMATION OF GOOD FAITH, and EXHIBITS SCAHILL LAW GROUP, P.C. Attorneys for Defendants LANETFE WOODDARD s/h/aLANETTE WOODARD 1065 Stewart Avenue, Suite210 Bethpage, New York 11714 (516)294-5200 ATTORNEY CERTIFICATION Pursuant to 22 NYCRR §130-1.1, the undersigned, an attorney admitted to practice in the courts of New York State, certifiesthat upon information and belief and responsible inquiry, the contentions contained in the annexed documents are not frivolous. Dated: April 22, 2020 ERIC C. FLORES Please take notice O Notice of entry that the within is a ( certified) true copy of a duly entered in the office of the clerk of the within named court on Oblotice of Settlement; ^ that an order of which the within is a true copy will be presented for settlement to the HON. one of the judges of the within named court, at on Dated: Bethpage, New York Yours, etc. SCAHILL LAW GROUP, P.C. Attorneys for Defendants LANETTE WOODDARD s/h/aLANETTE WOODARD 1065 Stewart Avenue, Suite 210 Bethpage, New York 11714 (516) 294-5200 4 of 4