Motion,Ex Parte: Jennifer D Milano v. Daniel A Milano

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                                FILED: NASSAU COUNTY CLERK 09/19/2023 12:38 PM                                                INDEX NO. 615191/2023
NYSCEF DOC. NO. 2                                                                     RECEIVED NYSCEF: 09/19/2023




             SUPREME COURT OF THE STATE OF NEW YORK
             COUNTY OF NASSAU

             JENNIFER D. MILANO,                                          Index:
                                            Plaintifl
                                                                          NOTICE OF MOTION
                                                                          FOR SUMMARY
                                                                          JUDGMENT IN LIEU
             DANIEL A. MILANO,                                            OF COMPLAINT
                                            Defendant.


                    PLEASE TAKE NOTICE that upon the attached affidavit and certification of

             JENNIFER D. MILANO, ("Plaintiff') duly sworn to on September 19, 2023, together

             with exhibits attached thereto, and upon the affirmation of Dennis J. McGrath, Esq., of

             McGrath Klaus and Associates, LLP, attorneys for Plaintiff, dated September 19,2023,

             Plaintiff will move this Court at the Courthouse located at 100 Supreme Court Drive,

             Mineola, New York 11501 on the 30th day of October,2023 at9:30 a.m. or as soon

             thereafter as counsel can be heard, for an order granting Plaintiffs Summary Judgment

             against the Defendant pursuant to Rule 3213 of the Civil Practice Law and Rules for the

             sum of $150,000.00 plus interest from October 08, 2020, upon the ground that this action

             is based upon an instrument for the payment of money only, which is now due            and

             payable and there are no defenses thereto, together with costs and disbursements and such

             other and further relief as may be just and proper.

                    The above-entitled action is to recover on an instrument for the payment of

             money only which is now due and payable.

                    PLEASE TAKE FURTHER NOTICE that pursuant to Rule 52214 of the CPLR

             answering affrdavits and any other papers in opposition to the motion, if any, are required




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FILED: NASSAU COUNTY CLERK 09/19/2023 12:38 PM                                            INDEX NO. 615191/2023
NYSCEF DOC. NO. 2                                                                   RECEIVED NYSCEF: 09/19/2023




            to be served upon the undersigned at least seven (7) days before the return date of this

             motion.

             Dated this 19th day of September ,2023.



                                                 Respectfully submitted,

                                                 McGRATH


                                                 By:
                                                                   McGrTth, Esq.
                                                                    for the Plaintiff
                                                                Broadway, Massapequa. NY 1 1758

                                                         dennis@goMKlaw.com


            to:     (Via Personal Service)
                    DANIEL A. MILANO
                    126 B TULIP COURT
                    MANCHESTER, NEW JERSEY 08759




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