On February 10, 2023 a
Party Notice
was filed
involving a dispute between
Louis Bombardier,
and
Jamie Menard,
for Commercial - Contract
in the District Court of Clinton County.
Preview
FILED: CLINTON COUNTY CLERK 02/17/2023 04:22 PM INDEX NO. 2023-00023095
NYSCEF DOC. NO. 11 RECEIVED NYSCEF: 02/17/2023
SUPREME COURT COUNTY OF CLINTON
LOUIS BOMBARDIER, NOTICE OF CROSS-MOTION
TO DISMISS
Plaintiff,
Index No. 2023-00023095
-against- Hon. Allison M. McGahay
JAMIE MENARD, ORAL ARGUMENT
Defendants. REQUESTED
PLEASE TAKE NOTICE that upon the Affirmation of Daniel S. L. Rubin, Esq., sworn to
on the 17th day of February, 2023; the Affidavit of Jamie Menard, sworn to on the 17th day of
February, 2023; and all prior pleadings, exhibits, and proceedings in this action, Defendant, by and
through his counsel, Girvin & Ferlazzo, P.C., will cross-move this Court (Hon. Allison M.
McGahay) pursuant to CPLR 3213 and CPLR 3211(a)(8), at the Supreme Court, Clinton County,
located at 137 Margaret Street, Plattsburgh, New York 12901 on the 23rd day of February, 2023,
at 10:00am in the forenoon of that day, or as soon thereafter as counsel can be heard, for an order
dismissing this action and granting such other and further relief as may be just, proper, and
equitable.
Dated: February 17, 2023 GIRVIN & FERLAZZO, P.C.
Albany, New York
By:
Daniel S. L. Rubin, Esq.
Bonnie R. Watson, Esq.
Attorneys for Defendant Jamie Menard
20 Corporate Woods Blvd., 2nd Floor
Albany, New York 12211
Telephone: (518) 462-0300
dsr@girvinlaw.com
brw@girvinlaw.com
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FILED: CLINTON COUNTY CLERK 02/17/2023 04:22 PM INDEX NO. 2023-00023095
NYSCEF DOC. NO. 11 RECEIVED NYSCEF: 02/17/2023
To: Justin R. Meyer, Esq.
Stafford, Owens, Murnane, Kelleher, Miller, Meyer & Zedick, PLLC
Attorneys for Plaintiff Louis Bombardier
One Cumberland Avenue
P.O. Box 2947
Plattsburgh, New York 12901
(518) 561-4400
justinmeyer@staffordowens.com
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2 of 2
Preview
FILED: CLINTON COUNTY CLERK 02/17/2023 04:22 PM INDEX NO. 2023-00023095 NYSCEF DOC. NO. 11 RECEIVED NYSCEF: 02/17/2023 SUPREME COURT COUNTY OF CLINTON LOUIS BOMBARDIER, NOTICE OF CROSS-MOTION TO DISMISS Plaintiff, Index No. 2023-00023095 -against- Hon. Allison M. McGahay JAMIE MENARD, ORAL ARGUMENT Defendants. REQUESTED PLEASE TAKE NOTICE that upon the Affirmation of Daniel S. L. Rubin, Esq., sworn to on the 17th day of February, 2023; the Affidavit of Jamie Menard, sworn to on the 17th day of February, 2023; and all prior pleadings, exhibits, and proceedings in this action, Defendant, by and through his counsel, Girvin & Ferlazzo, P.C., will cross-move this Court (Hon. Allison M. McGahay) pursuant to CPLR 3213 and CPLR 3211(a)(8), at the Supreme Court, Clinton County, located at 137 Margaret Street, Plattsburgh, New York 12901 on the 23rd day of February, 2023, at 10:00am in the forenoon of that day, or as soon thereafter as counsel can be heard, for an order dismissing this action and granting such other and further relief as may be just, proper, and equitable. Dated: February 17, 2023 GIRVIN & FERLAZZO, P.C. Albany, New York By: Daniel S. L. Rubin, Esq. Bonnie R. Watson, Esq. Attorneys for Defendant Jamie Menard 20 Corporate Woods Blvd., 2nd Floor Albany, New York 12211 Telephone: (518) 462-0300 dsr@girvinlaw.com brw@girvinlaw.com 1 1 of 2 FILED: CLINTON COUNTY CLERK 02/17/2023 04:22 PM INDEX NO. 2023-00023095 NYSCEF DOC. NO. 11 RECEIVED NYSCEF: 02/17/2023 To: Justin R. Meyer, Esq. Stafford, Owens, Murnane, Kelleher, Miller, Meyer & Zedick, PLLC Attorneys for Plaintiff Louis Bombardier One Cumberland Avenue P.O. Box 2947 Plattsburgh, New York 12901 (518) 561-4400 justinmeyer@staffordowens.com 2 2 of 2