Party Notice: Pearl Delta Funding, Llc v. Peak Title Agency Co. A/K/A PEAK TITLE CO, Tobby Jablonski, Juan Ruiz Jr

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                                FILED: NASSAU COUNTY CLERK 07/10/2023 04:14 AM                                                     INDEX NO. 600378/2023
NYSCEF DOC. NO. 56                                                                          RECEIVED NYSCEF: 07/10/2023




          SUPREME COURT OF THE STATE OF NEW YORK
          COUNTY OF NASSAU
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          PEARL DELTA FUNDING, LLC                                                   Index No.: 600378/2023
                                             PLAINTIFF,


                           -against-                                                 CROSS MOTION FOR
                                                                                     SUMMARY JUDGMENT


          PEAK TITLE AGENCY CO ET AL
                                             DEFENDANTS
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          PLEASE TAKE NOTICE, that upon the annexed affirmation of Dominick Dale, Esq, dated the

          JULY 10, 2023, PEAK TITLE AGENCY CO ET ALET AL, will move this Court at and IAS Part

          at the Courthouse located at Supreme Court County of Nassau located at 100 Supreme Court Drive

          Mineola, New York 11501 on the 17th day of July, 2023 at 9:30 a.m., or as soon thereafter as

          counsel can be heard, for an Order: 1) pursuant to CPLR § 3211(a)(5), dismissing plaintiff’s

          complaint with prejudice on the basis that it is barred by res judicata and this Court’s prior order

          dated June 20, 2023; 2) pursuant to CPLR § 3212, granting summary judgment in favor of PEAK

          TITLE AGENCY CO ET AL on the grounds that there exists no triable issues of material fact and

          3) for such and other relief the court may deem just and proper.



          PLEASE TAKE FURTHER NOTICE, that pursuant to CPLR 2214(b), answering affidavits if any,

          must be served upon the undersigned at least seven days before the return date of this motion.




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FILED: NASSAU COUNTY CLERK 07/10/2023 04:14 AM                            INDEX NO. 600378/2023
NYSCEF DOC. NO. 56                                                 RECEIVED NYSCEF: 07/10/2023




          Dated: Queens, New York
                 JULY 10, 2023




                                                    Respectfully submitted,

                                                    Dominick Dale, Esq.

                                                    Dominick Dale, Esq.
                                                    Law Office of Dominick Dale, Esq.
                                                    Attorneys for Defendant
                                                    70-02 Nansen Street
                                                    Forest Hills New York 11375
                                                    (917) 816-8327
          To:

          Christopher R. Murray, Esq.
          Murray Legal, PLLC
          170 Old Country Rd., Suite 608
          Mineola, New York 11501
          Tel: (516) 260-7367




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