On June 30, 2020 a
Motion,Ex Parte
was filed
involving a dispute between
Newtek Small Business Finance, Llc,
and
Michael J Liberman,
in the District Court of Nassau County.
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FILED: NASSAU COUNTY CLERK 05/24/2021 03:31 PM INDEX NO. 606560/2020
NYSCEF DOC. NO. 29 RECEIVED NYSCEF: 05/24/2021
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF NASSAU
-------------------------------------------------------------------X
NEWTEK SMALL BUSINESS FINANCE, LLC, Index No. 606560/2020
Plaintiff, NOTICE OF MOTION TO
RENEW
-against-
MICHAEL J. LIBERMAN,
Defendant.
-------------------------------------------------------------------X
PLEASE TAKE NOTICE that upon the Affidavit of Peter Persichette, sworn to on May
20, 2021, the Affirmation of J’Naia L. Boyd, dated May 24, 2021, and upon all of the pleadings
and proceedings heretofore had herein, Plaintiff Newtek Small Business Finance, LLC
(“Plaintiff”), by and through its attorneys, shall move this Court, at the courthouse located at 100
Supreme Court, Mineola, New York 11501, before Justice Jerome C. Murphy on June 14, 2021,
at 9:30 a.m. that day, or as soon thereafter as counsel can be heard for an order pursuant to C.P.L.R.
2221(e) granting renewal of Plaintiff’s prior motion seeking the entry of a judgment awarding
attorneys’ fees and expenses for Plaintiff and against Defendant, and for such other and further
relief as the Court may deem just and proper.
PLEASE TAKE FURTHER NOTICE that, pursuant to CPLR §2214 (b), answering
papers and/or cross-motions, if any, shall be served upon the undersigned no later than seven (7)
days prior to the return date of this motion.
1 of 2
FILED: NASSAU COUNTY CLERK 05/24/2021 03:31 PM INDEX NO. 606560/2020
NYSCEF DOC. NO. 29 RECEIVED NYSCEF: 05/24/2021
Dated: Uniondale, New York
May 24, 2021
Yours etc.,
RIVKIN RADLER LLP
By: /s/ J’Naia L. Boyd
Matthew V. Spero
J’Naia L. Boyd
926 RXR Plaza
Uniondale, New York 11556
Telephone: (516) 357-3000
Facsimile: (516) 357-3333
Attorneys for Plaintiff Newtek Small
Business Finance, LLC
TO: Michael J. Liberman
2655 Rachel Street
Bellmore, New York 11710
5243939.v1
2 of 2
Document Filed Date
May 24, 2021
Case Filing Date
June 30, 2020
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FILED: NASSAU COUNTY CLERK 05/24/2021 03:31 PM INDEX NO. 606560/2020 NYSCEF DOC. NO. 29 RECEIVED NYSCEF: 05/24/2021 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF NASSAU -------------------------------------------------------------------X NEWTEK SMALL BUSINESS FINANCE, LLC, Index No. 606560/2020 Plaintiff, NOTICE OF MOTION TO RENEW -against- MICHAEL J. LIBERMAN, Defendant. -------------------------------------------------------------------X PLEASE TAKE NOTICE that upon the Affidavit of Peter Persichette, sworn to on May 20, 2021, the Affirmation of J’Naia L. Boyd, dated May 24, 2021, and upon all of the pleadings and proceedings heretofore had herein, Plaintiff Newtek Small Business Finance, LLC (“Plaintiff”), by and through its attorneys, shall move this Court, at the courthouse located at 100 Supreme Court, Mineola, New York 11501, before Justice Jerome C. Murphy on June 14, 2021, at 9:30 a.m. that day, or as soon thereafter as counsel can be heard for an order pursuant to C.P.L.R. 2221(e) granting renewal of Plaintiff’s prior motion seeking the entry of a judgment awarding attorneys’ fees and expenses for Plaintiff and against Defendant, and for such other and further relief as the Court may deem just and proper. PLEASE TAKE FURTHER NOTICE that, pursuant to CPLR §2214 (b), answering papers and/or cross-motions, if any, shall be served upon the undersigned no later than seven (7) days prior to the return date of this motion. 1 of 2 FILED: NASSAU COUNTY CLERK 05/24/2021 03:31 PM INDEX NO. 606560/2020 NYSCEF DOC. NO. 29 RECEIVED NYSCEF: 05/24/2021 Dated: Uniondale, New York May 24, 2021 Yours etc., RIVKIN RADLER LLP By: /s/ J’Naia L. Boyd Matthew V. Spero J’Naia L. Boyd 926 RXR Plaza Uniondale, New York 11556 Telephone: (516) 357-3000 Facsimile: (516) 357-3333 Attorneys for Plaintiff Newtek Small Business Finance, LLC TO: Michael J. Liberman 2655 Rachel Street Bellmore, New York 11710 5243939.v1 2 of 2