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FILED: NASSAU COUNTY CLERK 12/01/2022 07:43 PM INDEX NO. 610946/2022
NYSCEF DOC. NO. 9 RECEIVED NYSCEF: 12/02/2022
NEW YORK STATE SUPREME COURT
COUNTY OF NASSAU
MASUDA BEGUM and MOTASHEM BILLAH,
NOTICE OF MOTION
Plaintiffs,
Index No. 610946/2022
v.
ASSOCIATED MUTUAL INSURANCE
COOPERATIVE, ERHARDT ADJUSTMENT CO.,
INC. and ALL DRY USA,
Defendants.
MOTION MADE BY: Defendant, ERHARDT ADJUSTMENT CO.,
INC., through its attorneys, Mura Law Group,
PLLC, 930 Rand Building, 14 Lafayette Square,
Buffalo, New York 14203.
DATE, TIME AND
PLACE OF HEARING: Monday, December 19, 2022, at 9:30 a.m. at
the Nassau County Supreme Court Courthouse,
100 Supreme Court Drive Mineola, New York
11501.
SUPPORTING PAPERS: This Notice of Motion, Affirmation of Roy A
Mura, Esq. dated December 1, 2022, with
attached exhibits, Affirmation of Tamara A.
Bland, Esq. dated December 1, 2022, Affidavit
of Thomas E. Erhardt sworn to on December 1,
2022, and Memorandum of Law in Support of
the motion, and all the pleadings and
proceedings heretofore had herein.
RELIEF DEMANDED
AND GROUNDS THEREFORE: (A) pursuant to CPLR 3012(d) compelling
plaintiffs to accept Erhardt’s verified answer,
dated and filed on November 30, 2022; and
(B) pursuant to CPLR 3211(a)(7)
dismissing plaintiffs’ complaint as against
Erhardt only, in its entirety and with
prejudice; and
-1-
MURA LAW GROUP, PLLC • 930 RAND BUILDING • 14 LAFAYETTE SQUARE • BUFFALO, NEW YORK 14203
(716) 855-2800 • FAX (716) 855-2816
1 of 2
FILED: NASSAU COUNTY CLERK 12/01/2022 07:43 PM INDEX NO. 610946/2022
NYSCEF DOC. NO. 9 RECEIVED NYSCEF: 12/02/2022
(C) for such other and different relief in
favor of the Erhardt as this Court deems just
and proper.
ANSWERING PAPERS: Answering affidavits, and any notices of cross
motion and supporting affidavits, if any, must
be served upon the undersigned at least seven
(7) days prior to the return date of this motion
in accordance with the requirements of CPLR
Article 2214(b).
ORAL ARGUMENT: Requested.
DATED: Buffalo, New York
December 2, 2022
____________________________________
Roy A. Mura, Esq.
Scott D. Mancuso, Esq.
MURA LAW GROUP, PLLC
Attorneys for Defendant
Erhardt Adjustment Co., Inc.
930 Rand Building
14 Lafayette Square
Buffalo, New York 14203
(716) 855-2800
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MURA LAW GROUP, PLLC • 930 RAND BUILDING • 14 LAFAYETTE SQUARE • BUFFALO, NEW YORK 14203
(716) 855-2800 • FAX (716) 855-2816
2 of 2
Preview
FILED: NASSAU COUNTY CLERK 12/01/2022 07:43 PM INDEX NO. 610946/2022 NYSCEF DOC. NO. 9 RECEIVED NYSCEF: 12/02/2022 NEW YORK STATE SUPREME COURT COUNTY OF NASSAU MASUDA BEGUM and MOTASHEM BILLAH, NOTICE OF MOTION Plaintiffs, Index No. 610946/2022 v. ASSOCIATED MUTUAL INSURANCE COOPERATIVE, ERHARDT ADJUSTMENT CO., INC. and ALL DRY USA, Defendants. MOTION MADE BY: Defendant, ERHARDT ADJUSTMENT CO., INC., through its attorneys, Mura Law Group, PLLC, 930 Rand Building, 14 Lafayette Square, Buffalo, New York 14203. DATE, TIME AND PLACE OF HEARING: Monday, December 19, 2022, at 9:30 a.m. at the Nassau County Supreme Court Courthouse, 100 Supreme Court Drive Mineola, New York 11501. SUPPORTING PAPERS: This Notice of Motion, Affirmation of Roy A Mura, Esq. dated December 1, 2022, with attached exhibits, Affirmation of Tamara A. Bland, Esq. dated December 1, 2022, Affidavit of Thomas E. Erhardt sworn to on December 1, 2022, and Memorandum of Law in Support of the motion, and all the pleadings and proceedings heretofore had herein. RELIEF DEMANDED AND GROUNDS THEREFORE: (A) pursuant to CPLR 3012(d) compelling plaintiffs to accept Erhardt’s verified answer, dated and filed on November 30, 2022; and (B) pursuant to CPLR 3211(a)(7) dismissing plaintiffs’ complaint as against Erhardt only, in its entirety and with prejudice; and -1- MURA LAW GROUP, PLLC • 930 RAND BUILDING • 14 LAFAYETTE SQUARE • BUFFALO, NEW YORK 14203 (716) 855-2800 • FAX (716) 855-2816 1 of 2 FILED: NASSAU COUNTY CLERK 12/01/2022 07:43 PM INDEX NO. 610946/2022 NYSCEF DOC. NO. 9 RECEIVED NYSCEF: 12/02/2022 (C) for such other and different relief in favor of the Erhardt as this Court deems just and proper. ANSWERING PAPERS: Answering affidavits, and any notices of cross motion and supporting affidavits, if any, must be served upon the undersigned at least seven (7) days prior to the return date of this motion in accordance with the requirements of CPLR Article 2214(b). ORAL ARGUMENT: Requested. DATED: Buffalo, New York December 2, 2022 ____________________________________ Roy A. Mura, Esq. Scott D. Mancuso, Esq. MURA LAW GROUP, PLLC Attorneys for Defendant Erhardt Adjustment Co., Inc. 930 Rand Building 14 Lafayette Square Buffalo, New York 14203 (716) 855-2800 -2- MURA LAW GROUP, PLLC • 930 RAND BUILDING • 14 LAFAYETTE SQUARE • BUFFALO, NEW YORK 14203 (716) 855-2800 • FAX (716) 855-2816 2 of 2