On October 01, 2018 a
Motion,Ex Parte
was filed
involving a dispute between
Marthe Milius,
and
Isabelle Charles,
for Torts - Other Negligence (PERSONAL INJURY)
in the District Court of Kings County.
Preview
FILED: KINGS COUNTY CLERK 02/21/2023 04:02 PM INDEX NO. 519726/2018
NYSCEF DOC. NO. 43 RECEIVED NYSCEF: 02/21/2023
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF KINGS
----------------------------------------------------------------------x Index No: 519726/2018
MARTHE MILIUS,
Plaintiff, NOTICE OF MOTION
-against-
ISABELLE CHARLES,
Defendant.
______________________________________________________________________Ç
PLEASE TAKE NOTICE that upon the annexed affirmation of MARK J. LINDER,
dated the February 16, 2023, and upon all papers pleadings and proceedings heretofore had and
filed herein, the undersigned will move this Court at the Motion Submission Part, at the Courthouse
16th
located at 360 Adams Street, Room 227 Brooklyn, NY 11201, on the day of March 2023 at
9:30 A.M., or as soon as counsel can be heard for an Order, pursuant to CPLR 602(a), directing
that Action No. 1 and Action No. 2 be tried together upon the ground that common questions of
law and fact are involved, and for such other and further relief as to this Court may deem just and
proper.
PLEASE TAKE FURTHER NOTICE, that pursuant to CPLR 2214(b), you are
required to serve all opposing papers at least seven (7) days prior to the return of this motion.
Dated: New York, New York
February 16, 2023
Yours, etc.,
HARMON LINDER & ROGOWSKY, ESQS.
Attorneys for Plaintiff
3 Park Avenue, Suite 2300,
New York, New York, 10016
(212) 732-3665
1 of 2
FILED: KINGS COUNTY CLERK 02/21/2023 04:02 PM INDEX NO. 519726/2018
NYSCEF DOC. NO. 43 RECEIVED NYSCEF: 02/21/2023
TO: SILVERMAN, SHIN & BYRNE, PLLC
Attorney(s)for Defendants in Action No.1
ISABELLE CHARLES
Wall Street Plaza
22nd
88 Pine Street, FlOOr
New York, New York 10005
(212) 779-8600
MOUND COTTON WOLLAN & GREENGRASS LLP
Attn: Labe Feldman, Esq.
Attorneys for Plaintiff in Action No. 2
MOUNTAIN VALLEY INDEMNITY COMPANY
44th
One New York Plaza, FlOOr
New York, NY 10004
(212) 804-4550
ANDREE SYLVESTRE-JOHNSON, ESQ.
Attorney(s) for Defendants in Action No.2
ISABELLE CHARLES
26 Court Street, Suite 2511
Brooklyn, New York 11242
(718) 403-0325
2
2 of 2
Preview
FILED: KINGS COUNTY CLERK 02/21/2023 04:02 PM INDEX NO. 519726/2018 NYSCEF DOC. NO. 43 RECEIVED NYSCEF: 02/21/2023 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF KINGS ----------------------------------------------------------------------x Index No: 519726/2018 MARTHE MILIUS, Plaintiff, NOTICE OF MOTION -against- ISABELLE CHARLES, Defendant. ______________________________________________________________________Ç PLEASE TAKE NOTICE that upon the annexed affirmation of MARK J. LINDER, dated the February 16, 2023, and upon all papers pleadings and proceedings heretofore had and filed herein, the undersigned will move this Court at the Motion Submission Part, at the Courthouse 16th located at 360 Adams Street, Room 227 Brooklyn, NY 11201, on the day of March 2023 at 9:30 A.M., or as soon as counsel can be heard for an Order, pursuant to CPLR 602(a), directing that Action No. 1 and Action No. 2 be tried together upon the ground that common questions of law and fact are involved, and for such other and further relief as to this Court may deem just and proper. PLEASE TAKE FURTHER NOTICE, that pursuant to CPLR 2214(b), you are required to serve all opposing papers at least seven (7) days prior to the return of this motion. Dated: New York, New York February 16, 2023 Yours, etc., HARMON LINDER & ROGOWSKY, ESQS. Attorneys for Plaintiff 3 Park Avenue, Suite 2300, New York, New York, 10016 (212) 732-3665 1 of 2 FILED: KINGS COUNTY CLERK 02/21/2023 04:02 PM INDEX NO. 519726/2018 NYSCEF DOC. NO. 43 RECEIVED NYSCEF: 02/21/2023 TO: SILVERMAN, SHIN & BYRNE, PLLC Attorney(s)for Defendants in Action No.1 ISABELLE CHARLES Wall Street Plaza 22nd 88 Pine Street, FlOOr New York, New York 10005 (212) 779-8600 MOUND COTTON WOLLAN & GREENGRASS LLP Attn: Labe Feldman, Esq. Attorneys for Plaintiff in Action No. 2 MOUNTAIN VALLEY INDEMNITY COMPANY 44th One New York Plaza, FlOOr New York, NY 10004 (212) 804-4550 ANDREE SYLVESTRE-JOHNSON, ESQ. Attorney(s) for Defendants in Action No.2 ISABELLE CHARLES 26 Court Street, Suite 2511 Brooklyn, New York 11242 (718) 403-0325 2 2 of 2