Preview
FILED: KINGS COUNTY CLERK 03/08/2022 02:31 PM INDEX NO. 528030/2019
NYSCEF DOC. NO. 20 RECEIVED NYSCEF: 03/08/2022
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF KINGS
_____________________________________Ç
ZESHAN MINHASS Index No: 528030/2019
and QASIM RASUL,
Plaintiffs,
- against -
OPEN ROAD FLEET INC
and NII LANTE LAMPTEY, NOTICE OF CROSS-MOTION
FOR SUMMARY JUDGMENT
Defendants.
______________________________________Ç
PLEASE TAKE NOTICE, that upon the annexed affirmation of
MELINDA KIRSCH, ESQ., dated March 8, 2022, and upon the exhibits
annexed hereto, and upon all the pleadings and proceedings
heretofore had herein, Plaintiffs ZESHAN MINHASS and QASIM RASUL,
in the above entitled action, will cross-move this Court at
Supreme Court of the State of New York, Kings County, located at
20*
360 Adams Street, Brooklyn, New York, on the day of April,
2022, before the Honorable Carl J. Landicino, J.S.C., for an
Order pursuant to CPLR 3212, granting Plaintiffs partial summary
judgment against Defendants on the issue of liability, setting
this matter down for a trial to assess damages only, and for such
other and further relief as this Court may deem just and proper
herein;
The above entitled action is for personal injuries and
property damage arising from a two car accident.
Pursuant to CPLR 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.
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FILED: KINGS COUNTY CLERK 03/08/2022 02:31 PM INDEX NO. 528030/2019
NYSCEF DOC. NO. 20 RECEIVED NYSCEF: 03/08/2022
Dated: New York, New York
March 8, 2022
LAW OFFICES OF
GLENN S. CAPLAN, P.C.
Attorne s for, P a'Itig
By: ü
MELINDA/kIRSCH
OFFICE & POST OFFIM ADDRESS
160 - 10th Floor
Broadway
New York, NY 10038
(212) 406-2181
TO: Baker, McEvoy, Morrissey
& Mos kovits, PC
Attorneys for Defendants
8th
One Metrotech Center,
Brooklyn, NY 11201
(212) 857-8230
File No. 1022125
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FILED: KINGS COUNTY CLERK 03/08/2022 02:31 PM INDEX NO. 528030/2019
NYSCEF DOC. NO. 20 RECEIVED NYSCEF: 03/08/2022
AFFIRMATION OF SERVICE BY MAIL
MELINDA KIRSCH, an attorney at law, affirms the following
under penalty of perjury pursuant to CPLR 2106:
I am over the age of 18, and reside at New York, NY, and I
am not a party to this action.
On March 8, 2022, I served the within NOTICE OF CROSS-MOTION
and AFFIRMATION IN SUPPORT on the attorneys of all parties to
this action, by mailing a true copy in a postpaid wrapper in a
post office box maintained by the United States Postal Service at
160 Broadway, New York, NY, 10038, directed to them at the
address shown, heretofore designated by them for that purpose.
Baker, McEvoy, Morrissey & Moskovits, PC
8"
One Metrotech Center, Fl.
Brooklyn, NY 11201
Dated: New York, NY
March 8, 2022
MELINDA KI SCH
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FILED: KINGS COUNTY CLERK 03/08/2022 02:31 PM INDEX NO. 528030/2019
NYSCEF DOC. NO. 20 RECEIVED NYSCEF: 03/08/2022
Index No: 528030 Year: 2019
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF KINGS
ZESHAN MINHASS
a n d QASIM RASUL,
Plaintiffs,
- a g a in s t -
OPEN ROAD FLEET INC
and NII LANTE LAMPTEY,
Defendants.
NOTICE OF CROSS-MOTION FOR SUMMARY JUDGMENT
LAw OFFICES OF
GLENN S. CAPLAN, P.C.
Attorney For Plaintif f
160 BROADWAY -10TH FLOOR
NEW YORK, NY 10038
...
PHONE 406 - 2181
(212)
FAX 732 - 1425
(212)
To:
4 of 4
Preview
FILED: KINGS COUNTY CLERK 03/08/2022 02:31 PM INDEX NO. 528030/2019 NYSCEF DOC. NO. 20 RECEIVED NYSCEF: 03/08/2022 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF KINGS _____________________________________Ç ZESHAN MINHASS Index No: 528030/2019 and QASIM RASUL, Plaintiffs, - against - OPEN ROAD FLEET INC and NII LANTE LAMPTEY, NOTICE OF CROSS-MOTION FOR SUMMARY JUDGMENT Defendants. ______________________________________Ç PLEASE TAKE NOTICE, that upon the annexed affirmation of MELINDA KIRSCH, ESQ., dated March 8, 2022, and upon the exhibits annexed hereto, and upon all the pleadings and proceedings heretofore had herein, Plaintiffs ZESHAN MINHASS and QASIM RASUL, in the above entitled action, will cross-move this Court at Supreme Court of the State of New York, Kings County, located at 20* 360 Adams Street, Brooklyn, New York, on the day of April, 2022, before the Honorable Carl J. Landicino, J.S.C., for an Order pursuant to CPLR 3212, granting Plaintiffs partial summary judgment against Defendants on the issue of liability, setting this matter down for a trial to assess damages only, and for such other and further relief as this Court may deem just and proper herein; The above entitled action is for personal injuries and property damage arising from a two car accident. Pursuant to CPLR 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 4 FILED: KINGS COUNTY CLERK 03/08/2022 02:31 PM INDEX NO. 528030/2019 NYSCEF DOC. NO. 20 RECEIVED NYSCEF: 03/08/2022 Dated: New York, New York March 8, 2022 LAW OFFICES OF GLENN S. CAPLAN, P.C. Attorne s for, P a'Itig By: ü MELINDA/kIRSCH OFFICE & POST OFFIM ADDRESS 160 - 10th Floor Broadway New York, NY 10038 (212) 406-2181 TO: Baker, McEvoy, Morrissey & Mos kovits, PC Attorneys for Defendants 8th One Metrotech Center, Brooklyn, NY 11201 (212) 857-8230 File No. 1022125 2 of 4 FILED: KINGS COUNTY CLERK 03/08/2022 02:31 PM INDEX NO. 528030/2019 NYSCEF DOC. NO. 20 RECEIVED NYSCEF: 03/08/2022 AFFIRMATION OF SERVICE BY MAIL MELINDA KIRSCH, an attorney at law, affirms the following under penalty of perjury pursuant to CPLR 2106: I am over the age of 18, and reside at New York, NY, and I am not a party to this action. On March 8, 2022, I served the within NOTICE OF CROSS-MOTION and AFFIRMATION IN SUPPORT on the attorneys of all parties to this action, by mailing a true copy in a postpaid wrapper in a post office box maintained by the United States Postal Service at 160 Broadway, New York, NY, 10038, directed to them at the address shown, heretofore designated by them for that purpose. Baker, McEvoy, Morrissey & Moskovits, PC 8" One Metrotech Center, Fl. Brooklyn, NY 11201 Dated: New York, NY March 8, 2022 MELINDA KI SCH 3 of 4 FILED: KINGS COUNTY CLERK 03/08/2022 02:31 PM INDEX NO. 528030/2019 NYSCEF DOC. NO. 20 RECEIVED NYSCEF: 03/08/2022 Index No: 528030 Year: 2019 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF KINGS ZESHAN MINHASS a n d QASIM RASUL, Plaintiffs, - a g a in s t - OPEN ROAD FLEET INC and NII LANTE LAMPTEY, Defendants. NOTICE OF CROSS-MOTION FOR SUMMARY JUDGMENT LAw OFFICES OF GLENN S. CAPLAN, P.C. Attorney For Plaintif f 160 BROADWAY -10TH FLOOR NEW YORK, NY 10038 ... PHONE 406 - 2181 (212) FAX 732 - 1425 (212) To: 4 of 4