On August 19, 2021 a
Motion,Ex Parte
was filed
involving a dispute between
Kathleen Petrovics,
and
Garnet Health Medical Center,
Horton Medical Center,
John Doe Company,
Mb Real Estate,
Medical Properties I Middletown, Llc,
Remedy Medical Properties, Inc,
Wallkill Medical Development, Llc,
for Torts - Other (Personal Injury)
in the District Court of Orange County.
Preview
FILED: ORANGE COUNTY CLERK 05/12/2022 12:15 PM INDEX NO. EF005836-2021
NYSCEF DOC. NO. 13 RECEIVED NYSCEF: 05/12/2022
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF ORANGE
KATHLEEN PETROVICS, Index No. EF005836-2021
Plaintiff,
-against- NOTICE OF MOTION
GARNET HEALTH MEDICAL CENTER,
MB REAL ESTATE, and JOHN DOE COMPANY,
Defendants.
PLEASE TAKE NOTICE that upon the annexed Affirmation of Evan M. Foulke
dated May 12, 2022 with accompanying exhibits, the Summons and Complaint, Affidavit of Service,
and upon all prior pleadings, the undersigned will move this Court at a motion term thereof, to be held
in and for the Supreme Court of the State ofNew York, County of Orange located at 285 Main Street,
10th
Goshen, New York, on the day of June, 2022 at 9:30 o'clock in the forenoon of said day, or as
soon thereafter as counsel can be heard for an Order pursuant to CPLR § 3025 granting leave of Court
to file and serve an Amended Complaint.
PLEASE TAKE FURTHER NOTICE, that pursuant to Rule 2214 of the CPLR copies
of allaffidavits, affinnations and exhibits served in opposition to this motion must be served upon the
office of the undersigned no later than seven (7) days prior to the return date listed above.
Dated: Goshen, New York
May 12, 2022 FOULKE LAW FIRM
By: s/Evan M. Foulke
Evan M. Foulke, Esq.
Attorneys for Plaintiff
3d
55 Main Street, Floor
Goshen, New York 10924
(845) 294-4308
Filedin Orange County 05/12/2022 12:15:50 PM $45.00 Bk: 1 of
5146 2 Pg: 699 Index: # EF005836-2021 Clerk:EBR
FILED: ORANGE COUNTY CLERK 05/12/2022 12:15 PM INDEX NO. EF005836-2021
NYSCEF DOC. NO. 13 RECEIVED NYSCEF: 05/12/2022
TO: Seamus P. Weir, Esq.
CATANIA, MOHON & RIDER, PLLC
Attorneys for Defendant
Garnet Health Medical Center
641 Broadway
Newburgh, NY 12550
845-565-1100
Robert Myers, Esq.
WILSON ELSER MOSKOWITZ EDELMAN & DICKER LLP
Attorneys for Defendant
MB Real Estate
150 E 42nd Street
New York, NY 10017
212-490-3000
2 of 2
Document Filed Date
May 12, 2022
Case Filing Date
August 19, 2021
Category
Torts - Other (Personal Injury)
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Preview
FILED: ORANGE COUNTY CLERK 05/12/2022 12:15 PM INDEX NO. EF005836-2021 NYSCEF DOC. NO. 13 RECEIVED NYSCEF: 05/12/2022 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF ORANGE KATHLEEN PETROVICS, Index No. EF005836-2021 Plaintiff, -against- NOTICE OF MOTION GARNET HEALTH MEDICAL CENTER, MB REAL ESTATE, and JOHN DOE COMPANY, Defendants. PLEASE TAKE NOTICE that upon the annexed Affirmation of Evan M. Foulke dated May 12, 2022 with accompanying exhibits, the Summons and Complaint, Affidavit of Service, and upon all prior pleadings, the undersigned will move this Court at a motion term thereof, to be held in and for the Supreme Court of the State ofNew York, County of Orange located at 285 Main Street, 10th Goshen, New York, on the day of June, 2022 at 9:30 o'clock in the forenoon of said day, or as soon thereafter as counsel can be heard for an Order pursuant to CPLR § 3025 granting leave of Court to file and serve an Amended Complaint. PLEASE TAKE FURTHER NOTICE, that pursuant to Rule 2214 of the CPLR copies of allaffidavits, affinnations and exhibits served in opposition to this motion must be served upon the office of the undersigned no later than seven (7) days prior to the return date listed above. Dated: Goshen, New York May 12, 2022 FOULKE LAW FIRM By: s/Evan M. Foulke Evan M. Foulke, Esq. Attorneys for Plaintiff 3d 55 Main Street, Floor Goshen, New York 10924 (845) 294-4308 Filedin Orange County 05/12/2022 12:15:50 PM $45.00 Bk: 1 of 5146 2 Pg: 699 Index: # EF005836-2021 Clerk:EBR FILED: ORANGE COUNTY CLERK 05/12/2022 12:15 PM INDEX NO. EF005836-2021 NYSCEF DOC. NO. 13 RECEIVED NYSCEF: 05/12/2022 TO: Seamus P. Weir, Esq. CATANIA, MOHON & RIDER, PLLC Attorneys for Defendant Garnet Health Medical Center 641 Broadway Newburgh, NY 12550 845-565-1100 Robert Myers, Esq. WILSON ELSER MOSKOWITZ EDELMAN & DICKER LLP Attorneys for Defendant MB Real Estate 150 E 42nd Street New York, NY 10017 212-490-3000 2 of 2