On March 12, 2018 a
Proof of Service
was filed
involving a dispute between
Thalia Agathocleous,
and
795 Fifth Avenue Corportation D B A The Pierre,
Ihms,Llc,
for Torts - Other (Premises)
in the District Court of Queens County.
Preview
FILED: QUEENS COUNTY CLERK 10/11/2021 12:12 PM INDEX NO. 703721/2018
NYSCEF DOC. NO. 104 RECEIVED NYSCEF: 10/11/2021
AFFIRMATION OF SERVICE BY NYSCEF AND EMAIL
Gene Novak, Esq., an attorney duly admitted to practice law in the Courts of the State of
New York, hereby affirms the following under penalty of perjury:
That I am not a party to this action am over 18 years of age and resides in Brooklyn, New
York.
That on October 11, 2021, I served a true copy of the annexed AFFIRMATION IN
OPPOSITION TO MOTION TO VACATE DEFAULT and for the following matter, by
transmitting the papers by electronic means through the New York State E-File System. I received
an email from the New York State E-File System indicating that the transmission was received and
delivered to all counsel in the action as indicated below:
TO: SACCO & FILLAS, LLP
Attorneys for Plaintiff
7*
31-19 Newtown Avenue, Floor
Astoria. New York 1 1 102
Furthermore, on October 11, 2021, I served a true copy of the annexed AFFIRMATION
IN OPPOSITION TO MOTION TO VACATE DEFAULT and for the following matter, by
emailing same to the following email address: jbaez@saccofillas.com.
Dated: Brooklyn, New York
October 1 1,2021
Gen 6 k, Esq.
1 of 2
FILED: QUEENS COUNTY CLERK 10/11/2021 12:12 PM INDEX NO. 703721/2018
NYSCEF DOC. NO. 104 RECEIVED NYSCEF: 10/11/2021
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF QUEENS Index No.: 709721/2018
THALIA AGATHOCLEOUS,
Plaintiff,
-against-
795 FIFTH AVENUE CORPORATION d/b/a THE PIERRE,
and IHMS, LLC,
Defendants.
AFFIRMATION IN OPPOSITION TO MOTION TO VACATE DEFAULT
__
McMAHON, MARTINE & GALLAGHER, LLP
Attorneys for Defendant
795 FIFTH AVENUE CORPORATION and IHMS, LLC
55 Washington Street, Suite 720
Brooklyn, New York 11201
Tel. (212) 747-1230
Pursuant to 22 NYCRR 130-1.1, the undersigned, an attorney admitted to practice in the courts
of New York State, certifies that, upon information and belief and reaso le inquiry, the
contentions contained in the annexed document are not frivolous.
Dated: October 11, 2021 Signature:................
. ......................
....................
Print Signer's Na : ene Novak, Esq.
2 of 2
Document Filed Date
October 11, 2021
Case Filing Date
March 12, 2018
Category
Torts - Other (Premises)
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Preview
FILED: QUEENS COUNTY CLERK 10/11/2021 12:12 PM INDEX NO. 703721/2018 NYSCEF DOC. NO. 104 RECEIVED NYSCEF: 10/11/2021 AFFIRMATION OF SERVICE BY NYSCEF AND EMAIL Gene Novak, Esq., an attorney duly admitted to practice law in the Courts of the State of New York, hereby affirms the following under penalty of perjury: That I am not a party to this action am over 18 years of age and resides in Brooklyn, New York. That on October 11, 2021, I served a true copy of the annexed AFFIRMATION IN OPPOSITION TO MOTION TO VACATE DEFAULT and for the following matter, by transmitting the papers by electronic means through the New York State E-File System. I received an email from the New York State E-File System indicating that the transmission was received and delivered to all counsel in the action as indicated below: TO: SACCO & FILLAS, LLP Attorneys for Plaintiff 7* 31-19 Newtown Avenue, Floor Astoria. New York 1 1 102 Furthermore, on October 11, 2021, I served a true copy of the annexed AFFIRMATION IN OPPOSITION TO MOTION TO VACATE DEFAULT and for the following matter, by emailing same to the following email address: jbaez@saccofillas.com. Dated: Brooklyn, New York October 1 1,2021 Gen 6 k, Esq. 1 of 2 FILED: QUEENS COUNTY CLERK 10/11/2021 12:12 PM INDEX NO. 703721/2018 NYSCEF DOC. NO. 104 RECEIVED NYSCEF: 10/11/2021 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF QUEENS Index No.: 709721/2018 THALIA AGATHOCLEOUS, Plaintiff, -against- 795 FIFTH AVENUE CORPORATION d/b/a THE PIERRE, and IHMS, LLC, Defendants. AFFIRMATION IN OPPOSITION TO MOTION TO VACATE DEFAULT __ McMAHON, MARTINE & GALLAGHER, LLP Attorneys for Defendant 795 FIFTH AVENUE CORPORATION and IHMS, LLC 55 Washington Street, Suite 720 Brooklyn, New York 11201 Tel. (212) 747-1230 Pursuant to 22 NYCRR 130-1.1, the undersigned, an attorney admitted to practice in the courts of New York State, certifies that, upon information and belief and reaso le inquiry, the contentions contained in the annexed document are not frivolous. Dated: October 11, 2021 Signature:................ . ...................... .................... Print Signer's Na : ene Novak, Esq. 2 of 2