Motion,Ex Parte: Ryan Urban, Gigi Group, Llc v. Hudson Capital Group Ventures, Llc

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                                FILED: NEW YORK COUNTY CLERK 08/01/2023 08:51 AM                                              INDEX NO. 651660/2023
NYSCEF DOC. NO. 12                                                                     RECEIVED NYSCEF: 08/01/2023




             SUPREME COURT OF THE STATE OF NEW YORK
             IN AND FOR THE COUNTY OF NEW YORK

              RYAN URBAN and GIGI GROUP, LLC,
                                                                                    Index No. 651660/2023 .
                                             Plaintiffs,
                                                                                    NOTICE OF MOTION
                              ~ versus ~

              HUDSON CAPITAL GROUP VENTURES, LLC,                                        MOTION #001
                                                                                      Motion to Dismiss
                                             Defendant.                               Amended Complaint


                             PLEASE TAKE NOTICE, that upon the annexed Memorandum of Law,

             the Affirmation in Support by Counsel Gottesman, and the Memorandum of Law in

             Support by the Defendant, as well as all prior filings in this Matter the Defendant will

             respectfully Move before the Honorable Court at the Courthouse of the Supreme Court of

             the State of New York in and for New York County located at 60 Centre Street, New York,

             New York 10007, Motion Submission Part Courtroom 130 on August 21, 2023 at

             10:00 A.M., or as soon thereafter as Counsel may be heard for:

                     (i.)    an Order pursuant to C.P.L.R. §§ 3211(a)(1), (2) & (7); and other relevant

                             provisions of New York law and practice dismissing all Causes of Action by

                             All Parties, and Dismissing the entirety of the Amended Complaint with

                             Prejudice;

                     (ii.)   such other and further relief as this Court may deem just and proper.




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FILED: NEW YORK COUNTY CLERK 08/01/2023 08:51 AM                                             INDEX NO. 651660/2023
NYSCEF DOC. NO. 12                                                                     RECEIVED NYSCEF: 08/01/2023




                     PLEASE TAKE NOTICE that pursuant to C.P.L.R. § 2214(b), answering

             affidavits and notice of any cross-motion with supporting papers, if any, must be served on

             the undersigned at least seven days prior to the return date of this Motion.



             DATED:         July 30, 2023


                                                            RESPECTFULLY SUBMITTED,


                                                   By:
                                                            Baruch S. Gottesman, Esq.
                                                            New York Bar No. 4480539
                                                            GOTTESMAN LEGAL PLLC
                                                            11 Broadway, Suite 615
                                                            New York, NY 10004
                                                            Phone: (212) 401-6910
                                                            Fax: (212) 859-7307
                                                            bg@gottesmanlegal.com
                                                            Attorney for Defendant

             Served via NYSCEF on all appearing parties




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