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  • Angela Citro v. Jason AlbrechtsenTorts - Other (Replevin) document preview
  • Angela Citro v. Jason AlbrechtsenTorts - Other (Replevin) document preview
  • Angela Citro v. Jason AlbrechtsenTorts - Other (Replevin) document preview
  • Angela Citro v. Jason AlbrechtsenTorts - Other (Replevin) document preview
						
                                

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FILED: DUTCHESS COUNTY CLERK 01/11/2023 11:23 AM INDEX NO. 2022-53667 NYSCEF DOC. NO. 6 RECEIVED NYSCEF: 01/11/2023 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF DUTCHESS ANGELA CITRO NOTICE OF MOTION Plaintiff, Index No. 2022-53667 -against- JASON ALBRECHTSEN, Defendant. PLEASE TAIO NOTICE that: A. Upon 118¹ a. the annexed Affirmation of Jad B. Haddad, Esq., affirmed the day of January, 2023; b. the exhibits attached to each of the foregoing, and upon all the proceedings in this case to date; B. The Plaintiff, ANGELA CITRO, will move this Court at a term to be held thereof: 273¹ a. on the day of January 2023 at 9:30 a.m. or soon thereafter the Counsel can be heard; C, At the Courthouse located at 10 Market Street, Poughkeepsie, New York 12601, for an Order granting the following relief: i. Granting the Plaintiff, a default judgment against Defendant, JASON ALBRECHTSEN, for his failure to appear or otherwise move with respect to the Complaint; ii. Issuing a Judgment and Writ of Replevin awarding possession of the "6" personal property described in paragraph of the Verified 1 1 of 2 FILED: DUTCHESS COUNTY CLERK 01/11/2023 11:23 AM INDEX NO. 2022-53667 NYSCEF DOC. NO. 6 RECEIVED NYSCEF: 01/11/2023 Complaint, or, in the alternative for a Judgment in the amount of the property's value, $17,030.00, plus interest at a rate permitted by CPLR §5001 and §5004; iii. Issuing a judgment for money damages, calculated as described in "9" paragraph of the Verified Complaint, from Defendant in the amount of $31,671.38, plus interest at a rate permitted by CPLR §5001 and §5004; and . iv. Granting such other and further relief as the Court deems just and proper. X To be electronically filed. _X__ Courtesy copy to chambers. DATED: January [_, 2023 Wappingers Falls, New York AD B. HAI5ÍfAD, ESQ. STENGER, DIAMOND, & GLASS LLP Attorneys for Plaintiff 1136 Route 9 Wappingers Falls, New York 12590 jhaddad@sdglaw.com (845) 298-2000 TO: JASON ALBRECHTSEN 79 Smith Crossing Road Wappinger Falls, NY 12590 2 of 2