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FILED: NASSAU COUNTY CLERK 01/12/2021 10:28 AM INDEX NO. 618235/2019
NYSCEF DOC. NO. 10 RECEIVED NYSCEF: 01/12/2021
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF NASSAU
-----------------------------------------------------------------------X
MARTHA N. MENDOZA, Index No.: 618235/2019
Plaintiff(s),
NOTICE OF MOTION
-against- (MOTION Seq. #1)
ASHOK KUMAR, DEEPAK SHARMA, Return to: Hon. Justice
James P. McCormack
Defendant(s).
-----------------------------------------------------------------------X Return Date: 02/[ t/21
PLEASE TAKE NOTICE, that upon the annexed Affirmation of YAKOV
MUSHIYEV, ESQ., duly affirmed on January É, 2021, theAffidavit ofplaintiff MARTHA N.
MENDOZA, duly sworn to on January Ê, 2021, together with the exhibits annexed thereto, and
upon all ofthe pleadings and prior proceedings had herein, the undersigned will move in this Court
4th
at Part 18, Courtroom on the FlOOr North, thereof, to be held at the Courthouse, located at
100 Supreme Court Drive, Mineola, New York 11501, on the É day of February 2o_ 11
2021 at 9:30 o'clock in the forenoon of that day or as soon thereafter as counsel can be heard,
for an Order granting plaintiff summary judgment pursuant to CPLR §3212 as against
defendants ASHOK KUMAR and DEEPAK SHARMA, on the issue of liability, and granting
such other and further relief as this Court may deem just and proper.
PLEASE TAKE FURTHER NOTICE, that pursuant to CPLR §2214(b), you are
hereby required to serve copies of your answering affidavits on the undersigned no later than
the seventh day prior to the date set forth above for the submission of this motion.
Dated: Rosedale, New York
January u_, 2021
Yours, etc.,
YAKOV MUSHIYEV & ASSOCIATES, P.C.
By: /
AKOV SHIYEV, ES .
1 of 3
FILED: NASSAU COUNTY CLERK 01/12/2021 10:28 AM INDEX NO. 618235/2019
NYSCEF DOC. NO. 10 RECEIVED NYSCEF: 01/12/2021
Attorneys for Plaintiff
MARTHA N. MENDOZA
One Cross Island Plaza, Suite 325
Rosedale, NY 11422
Tel: (718) 775-3110
Our File No.: YM-19-052
TO: BAKER, MCEVOY, MOSKOVITS & LEVEN, PC
Attorney(s) for Defendants
ASHOK KUMAR and DEEPAK SHARMA
8th
One MetroTech Center, PlOOr
Brooklyn, New York 11201
Tel: (212) 857-8230
2 of 3
FILED: NASSAU COUNTY CLERK 01/12/2021 10:28 AM INDEX NO. 618235/2019
NYSCEF DOC. NO. 10 RECEIVED NYSCEF: 01/12/2021
Index No.: 618235/2019
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF NASSAU
******************************************************************************
MARTHA N. MENDOZA,
Plaintiff(s),
-against-
ASHOK KUMAR, DEEPAK SHARMA,
Defendant(s).
******************************************************************************
======--·======--==========--=====--==--===--=--=====--=======--===========
NOTICE OF MOTION FOR SUMMARY JUDGMENT ON LIABILITY
and AFFIRMATION IN SUPPORT
YAKOV MUSHIYEV & ASSOCIATES, P.C.
Attorney(s) for Plaintiff
MARTHA N. MENDOZA
One Cross Island Plaza, Suite 325
Rosedale, NY 11422
Tel: (718) 775-3110
Our File No.: YM-19-052
The best of my knowledge, information and belief, formed after an inquiry reasonable under the
fr'
circumstances, the presentation of this document, or the contentions contained 1erein, a not lous.
Dated: January 2021 Signature:
Print Signer's me: YA V MUSHIY E
Service of a copy of the within is hereby admitted.
Dated, , 2021
Attorney(s) for
Sir: Please take notice
o NOTICE OF ENTRY
that the within is a (certified) true copy of a
duly entered in the office of the Clerk of the within named Court on
o NOTICE OF SETTLEMENT
that an order of which the within is a true copy will be presented
for settlement to the HON. one of the Judges of the within named
Court, at
on he dayof at m
3 of 3
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FILED: NASSAU COUNTY CLERK 01/12/2021 10:28 AM INDEX NO. 618235/2019 NYSCEF DOC. NO. 10 RECEIVED NYSCEF: 01/12/2021 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF NASSAU -----------------------------------------------------------------------X MARTHA N. MENDOZA, Index No.: 618235/2019 Plaintiff(s), NOTICE OF MOTION -against- (MOTION Seq. #1) ASHOK KUMAR, DEEPAK SHARMA, Return to: Hon. Justice James P. McCormack Defendant(s). -----------------------------------------------------------------------X Return Date: 02/[ t/21 PLEASE TAKE NOTICE, that upon the annexed Affirmation of YAKOV MUSHIYEV, ESQ., duly affirmed on January É, 2021, theAffidavit ofplaintiff MARTHA N. MENDOZA, duly sworn to on January Ê, 2021, together with the exhibits annexed thereto, and upon all ofthe pleadings and prior proceedings had herein, the undersigned will move in this Court 4th at Part 18, Courtroom on the FlOOr North, thereof, to be held at the Courthouse, located at 100 Supreme Court Drive, Mineola, New York 11501, on the É day of February 2o_ 11 2021 at 9:30 o'clock in the forenoon of that day or as soon thereafter as counsel can be heard, for an Order granting plaintiff summary judgment pursuant to CPLR §3212 as against defendants ASHOK KUMAR and DEEPAK SHARMA, on the issue of liability, and granting such other and further relief as this Court may deem just and proper. PLEASE TAKE FURTHER NOTICE, that pursuant to CPLR §2214(b), you are hereby required to serve copies of your answering affidavits on the undersigned no later than the seventh day prior to the date set forth above for the submission of this motion. Dated: Rosedale, New York January u_, 2021 Yours, etc., YAKOV MUSHIYEV & ASSOCIATES, P.C. By: / AKOV SHIYEV, ES . 1 of 3 FILED: NASSAU COUNTY CLERK 01/12/2021 10:28 AM INDEX NO. 618235/2019 NYSCEF DOC. NO. 10 RECEIVED NYSCEF: 01/12/2021 Attorneys for Plaintiff MARTHA N. MENDOZA One Cross Island Plaza, Suite 325 Rosedale, NY 11422 Tel: (718) 775-3110 Our File No.: YM-19-052 TO: BAKER, MCEVOY, MOSKOVITS & LEVEN, PC Attorney(s) for Defendants ASHOK KUMAR and DEEPAK SHARMA 8th One MetroTech Center, PlOOr Brooklyn, New York 11201 Tel: (212) 857-8230 2 of 3 FILED: NASSAU COUNTY CLERK 01/12/2021 10:28 AM INDEX NO. 618235/2019 NYSCEF DOC. NO. 10 RECEIVED NYSCEF: 01/12/2021 Index No.: 618235/2019 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF NASSAU ****************************************************************************** MARTHA N. MENDOZA, Plaintiff(s), -against- ASHOK KUMAR, DEEPAK SHARMA, Defendant(s). ****************************************************************************** ======--·======--==========--=====--==--===--=--=====--=======--=========== NOTICE OF MOTION FOR SUMMARY JUDGMENT ON LIABILITY and AFFIRMATION IN SUPPORT YAKOV MUSHIYEV & ASSOCIATES, P.C. Attorney(s) for Plaintiff MARTHA N. MENDOZA One Cross Island Plaza, Suite 325 Rosedale, NY 11422 Tel: (718) 775-3110 Our File No.: YM-19-052 The best of my knowledge, information and belief, formed after an inquiry reasonable under the fr' circumstances, the presentation of this document, or the contentions contained 1erein, a not lous. Dated: January 2021 Signature: Print Signer's me: YA V MUSHIY E Service of a copy of the within is hereby admitted. Dated, , 2021 Attorney(s) for Sir: Please take notice o NOTICE OF ENTRY that the within is a (certified) true copy of a duly entered in the office of the Clerk of the within named Court on o NOTICE OF SETTLEMENT that an order of which the within is a true copy will be presented for settlement to the HON. one of the Judges of the within named Court, at on he dayof at m 3 of 3