On May 10, 2019 a
Party Notice
was filed
involving a dispute between
Nicholas Grant,
and
147-02 12 Liberty Ave., Llc.,
Isaac Rios Jr,
Jouvay Ny, Inc.,
Jouvay Ny, Inc. D B A Jouvay Night Club,
Professional Corporate Security Services, Inc.,
for Torts - Motor Vehicle
in the District Court of Kings County.
Preview
FILED: KINGS COUNTY CLERK 09/05/2023 04:20 PM INDEX NO. 510433/2019
NYSCEF DOC. NO. 105 RECEIVED NYSCEF: 09/05/2023
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF KINGS
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NICHOLAS GRANT,
NOTICE OF
Plaintiff(s), CROSS-MOTION
-against- Returnable: 9/13/23
147-02/12 LIBERTY AVE, LLC, JOUVAY NY, INC.
d/b/a JOUVAY NIGHT CLUB, ISAAC J. RIOS,
and PROFESSIONAL CORPORATE SECURITY
SEVICES, INC.,
Defendant(s).
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PLEASE TAKE NOTICE, that upon the affirmation of NEIL J. PALMIERI, affirmed on
the 5th day of September, 2023, and upon exhibits annexed thereto, the defendant, JOUVAY NY
INC. d/b/a JOUVAY NIGHT CLUB, will cross move this Court at the Courthouse located at 360
Adams Street, Brooklyn, New York, 11201, Moton Support Office, Room 227, on the 13th day of
September at 9:30 a.m. or as soon thereafter as counsel may be heard, for an order pursuant to CPLR §§ 3124
and 3126 striking the complaint for failing to appear for deposition without good cause and contumacious
refusal to comply with this court’s Case Scheduling and Central Compliance Part Conference Orders or
alternative, compelling plaintiff to appear for deposition forthwith along with such other, further and different
relieve as this Court deems just, proper and equitable.
PLEASE TAKE FURTHER NOTICE, that pursuant to CPLR 2214 (b), answering affidavits, if
any, must be served at least two (2) days prior to the return date of this cross-motion.
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FILED: KINGS COUNTY CLERK 09/05/2023 04:20 PM INDEX NO. 510433/2019
NYSCEF DOC. NO. 105 RECEIVED NYSCEF: 09/05/2023
Dated: Mineola, New York
September 5, 2023
Yours, etc.
BONGIORNO, MONTIGLIO, MITCHELL
& PALMIERI, PLLC
Neil J. Palmieri
By: Neil J. Palmieri, Esq.
Attorneys for JOUVAY NY INC. d/b/a
JOUVAY NIGHT CLUB
200 Old Country Road, Suite 680
Mineola, New York 11501
(516) 620-4490
Our File No.: FRS 016421 NJP
To: Law Offices of Bryan Barenbaum
Attorneys for Plaintiff
2060 Eastern Parkway
Brooklyn, New York 11207
(718) 421-1111
Black Marjieh & Sanford, LLP
Attorneys for 147-02/12 Liberty Ave., LLC
100 Clearbrook Road
Elmsford, New York 10523
(914) 704-4400
Goetz Schenker Blee & Wiederhorn
Professional Corporate Security Services, Inc.
101 Greenwich Street, 20th Floor
New York, New York 10006
(212) 363-6900
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