On June 14, 2021 a
Motion,Ex Parte
was filed
involving a dispute between
Jael Tusa Quinga,
and
Britneytusa Quinga
As Administrator Of The Estate Of Leonel G Tusa Masaquiza, Deceased,
Ftl 1001, Llc,
Paudy A. Nunez-Arias,
Rigo Limo-Auto Corp.,
The Estate Of Leonel G Tusa Masaquiza, Deceased,
for Torts - Motor Vehicle
in the District Court of Kings County.
Preview
FILED: KINGS COUNTY CLERK 09/01/2021 12:31 PM INDEX NO. 514355/2021
NYSCEF DOC. NO. 14 RECEIVED NYSCEF: 09/01/2021
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF KINGS
---------------------------------------------------------------------------X INDEX NO.: 514355/2021E
JAEL TUSA QUINGA,
Plaintiff(s), ACTION NO. 1
- against - NOTICE OF MOTION
FOR JOINT TRIAL
BRITNEYTUSA QUINGA, as Administrator of the
Estate of LEONEL G TUSA MASAQUIZA,
FTL 1001 LLC, RIGO LIMO-AUTO CORP.
and PAUDY A. NUNEZ-ARIAS,
Defendant(s).
----------------------------------------------------------------------------X File No.: 1031106
S I R (S):
PLEASE TAKE NOTICE, that upon the Affirmation of RONIT Z. MOSKOVITS,
ESQ., dated August 27, 2021, and the Exhibits annexed thereto, and upon all of the pleadings
and proceedings heretofore had herein, the undersigned will move this Court at Part thereof, to
be held at the Supreme Court Building Courthouse located at 360 Adams Street, Brooklyn, New
York 11201, on the 28th day September, 2021, at 09:30am in the forenoon of that day, or as soon
thereafter as counsel can be heard, for an Order, pursuant to CPLR 602(a), directing that Action
No. 1 be consolidated with Action No. 2 for the purposes of joint trial and any remaining
discovery proceedings, and for such other and further relief as to this Court may deem just and
proper.
PLEASE TAKE FURTHER NOTICE, that pursuant to C.P.L.R. 2214(b)
answering affidavits, if any, are required to be served upon the undersigned at least seven (7)
days before the return date of this Motion.
1 of 2
FILED: KINGS COUNTY CLERK 09/01/2021 12:31 PM INDEX NO. 514355/2021
NYSCEF DOC. NO. 14 RECEIVED NYSCEF: 09/01/2021
Dated: Brooklyn, New York
August 27, 2021
Yours, etc.,
BAKER, McEVOY & MOSKOVITS, P.C.
Attorneys for Defendant(s)
FTL 1001 LLC,
Rigo Limo-Auto Corp.
and Paudy Nunez-Arias
One Metrotech Center
Brooklyn, N.Y. 11201
(212) 875-8230
Mailing Address
5 Broadway, Ste 3
Freeport, NY 11520
TO: EUGENE M. BELLEN, ESQ.
Attorneys for Plaintiff in Action No. 1
485 MADISON AVE., 16TH FLR
NEW YORK, NY 10022
(212) 267-9100
MICHELSTEIN & ASHMAN, PLLC
Attorneys for Plaintiffs in Action No. 2
485 MADISON AVE., 16TH FLR
NEW YORK, NY 10022
(212) 588-0880
JAMES G. BILELLO & ASSOCIATES
Attorneys for Defendant in Action No. 1
100 DUFFY AVE., STE 500
HICKSVILLE, NY 11801
(516) 229-4321
File No.: 21-0074506
2 of 2
Preview
FILED: KINGS COUNTY CLERK 09/01/2021 12:31 PM INDEX NO. 514355/2021 NYSCEF DOC. NO. 14 RECEIVED NYSCEF: 09/01/2021 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF KINGS ---------------------------------------------------------------------------X INDEX NO.: 514355/2021E JAEL TUSA QUINGA, Plaintiff(s), ACTION NO. 1 - against - NOTICE OF MOTION FOR JOINT TRIAL BRITNEYTUSA QUINGA, as Administrator of the Estate of LEONEL G TUSA MASAQUIZA, FTL 1001 LLC, RIGO LIMO-AUTO CORP. and PAUDY A. NUNEZ-ARIAS, Defendant(s). ----------------------------------------------------------------------------X File No.: 1031106 S I R (S): PLEASE TAKE NOTICE, that upon the Affirmation of RONIT Z. MOSKOVITS, ESQ., dated August 27, 2021, and the Exhibits annexed thereto, and upon all of the pleadings and proceedings heretofore had herein, the undersigned will move this Court at Part thereof, to be held at the Supreme Court Building Courthouse located at 360 Adams Street, Brooklyn, New York 11201, on the 28th day September, 2021, at 09:30am in the forenoon of that day, or as soon thereafter as counsel can be heard, for an Order, pursuant to CPLR 602(a), directing that Action No. 1 be consolidated with Action No. 2 for the purposes of joint trial and any remaining discovery proceedings, and for such other and further relief as to this Court may deem just and proper. PLEASE TAKE FURTHER NOTICE, that pursuant to C.P.L.R. 2214(b) answering affidavits, if any, are required to be served upon the undersigned at least seven (7) days before the return date of this Motion. 1 of 2 FILED: KINGS COUNTY CLERK 09/01/2021 12:31 PM INDEX NO. 514355/2021 NYSCEF DOC. NO. 14 RECEIVED NYSCEF: 09/01/2021 Dated: Brooklyn, New York August 27, 2021 Yours, etc., BAKER, McEVOY & MOSKOVITS, P.C. Attorneys for Defendant(s) FTL 1001 LLC, Rigo Limo-Auto Corp. and Paudy Nunez-Arias One Metrotech Center Brooklyn, N.Y. 11201 (212) 875-8230 Mailing Address 5 Broadway, Ste 3 Freeport, NY 11520 TO: EUGENE M. BELLEN, ESQ. Attorneys for Plaintiff in Action No. 1 485 MADISON AVE., 16TH FLR NEW YORK, NY 10022 (212) 267-9100 MICHELSTEIN & ASHMAN, PLLC Attorneys for Plaintiffs in Action No. 2 485 MADISON AVE., 16TH FLR NEW YORK, NY 10022 (212) 588-0880 JAMES G. BILELLO & ASSOCIATES Attorneys for Defendant in Action No. 1 100 DUFFY AVE., STE 500 HICKSVILLE, NY 11801 (516) 229-4321 File No.: 21-0074506 2 of 2