Motion,Ex Parte: Wells Fargo Bank, N.A. v. Rodney Sapini, Stacey Sarnicola, New York City Transit Adjudication Bureau, New York City Environmental Control Board, New York City Parking Violations Bureau, John Does And Jane Does, Said Names Being Fictitious, Parties Intended Being Possible Tenants Or Occupants Of Premises And Corporations, Other Entities Or Persons Who Have Claim Or May Claim A Lien Against, Or Other Interest In The Premises

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                                FILED: KINGS COUNTY CLERK 06/03/2022 02:55 PM                                                                 INDEX NO. 506788/2015
NYSCEF DOC. NO. 152                                                                                 RECEIVED NYSCEF: 06/03/2022




          SUPREME COURT OF THE STATE OF NEW YORK
          COUNTY OF KINGS
                                                                                            x
          WELLS FARGO BANK, N.A.,                                                           :   Index No.: 506788/2015
                                                                                            :
                                                                              Plaintiff,    :   Mortgaged Premises:
                                                                                            :   451 74TH STREET
                       -against-                                                            :   BROOKLYN, NY 11209-2601
                                                                                            :
          RODNEY SAPINI; STACEY SARNICOLA; NEW YORK CITY                                    :   SBL #:
          TRANSIT ADJUDICATION BUREAU; NEW YORK CITY                                        :   Block: 5919
          ENVIRONMENTAL CONTROL BOARD; NEW YORK CITY                                        :   Lot: 57
          PARKING VIOLATIONS BUREAU; “JOHN DOES” and                                        :
          “JANE DOES”, said names being fictitious, parties intended                        :
          being possible tenants or occupants of premises and corporations,                 :   NOTICE OF MOTION
          other entities or persons who have, claim, or may claim, a lien                   :
          against, or other interest in, the premises,                                      :
                                                                                            :
                                                                         Defendant(s).      :
          -------------------------------------------------------------------------------   x


                  PLEASE TAKE NOTICE that, upon the accompanying Affirmation of Richard A. Sillett,

          dated June 3, 2022, in support of Plaintiff’s Motion to Compel Defendants Rodney Sapini and

          Stacey Sarnicola to Appear for Examinations Before Trial, with the exhibits annexed thereto; and

          the accompanying Affirmation of Good Faith of Richard A. Sillett, dated June 3, 2022, with the

          exhibits annexed thereto, Plaintiff will move this Court before Hon. Cenceria P. Edwards,

          Supreme Court of the State of New York, Kings County, at the Courthouse located at 360 Adams

          Street, Brooklyn, New York 11201, on June 29, 2022, at 9:30 a.m., or a soon thereafter as

          counsel can be heard, for an order granting Plaintiff’s motion to compel the deposition testimony

          of defendants Rodney Sapini and Stacey Sarnicola. An affirmation that a good-faith effort has

          been made to resolve the issues raised in this motion is annexed hereto.




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FILED: KINGS COUNTY CLERK 06/03/2022 02:55 PM                                                 INDEX NO. 506788/2015
NYSCEF DOC. NO. 152                                                                   RECEIVED NYSCEF: 06/03/2022




                 PLEASE TAKE FURTHER NOTICE that pursuant to CPLR 2214(b), answering

          affidavits, notices of cross-motion and other papers, if any, shall be served upon the undersigned

          at least seven days before the return date of this motion.


          Washington, D.C.
          June 3, 2022

                                                                ____________________________________

                                                                Richard A. Sillett




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