Motion,Ex Parte: Vox Funding Llc v. A Galaxy Of Stars Child Care Center, Llc, Lashunda Anteece Lane Glasgow

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                                FILED: NASSAU COUNTY CLERK 06/06/2023 04:03 PM                                                  INDEX NO. 607877/2023
NYSCEF DOC. NO. 6                                                                       RECEIVED NYSCEF: 06/06/2023




          SUPREME COURT OF THE STATE OF NEW YORK
          COUNTY OF NASSAU
                                                                           X
          VOX FUNDING LLC
                                                                                  NOTICE OF
                                               Plaintiff,
                                                                               MOTION TO DISMISS
                                 -against-

          A GALAXY OF STARS CHILD CARE CENTER, LLC
                                                                               Index No.: 607877/2023
          AND LASHUNDA ANTEECE LANE GLASGOW,
                                   Defendant.
                                                                           X

                    PLEASE TAKE NOTICE that, upon the annexed Affirmation of Dominick Dale, Esq.

          dated June 6, 2023, exhibits annexed thereto, the accompanying Memorandum of Law, and upon

          all the papers and proceedings heretofore had herein, the undersigned will move this Court on

          behalf of Defendant, A Galaxy of Stars Child Care Center Llc, et al at the Courthouse located at

          100 Supreme Court Drive, Mineola, NY 11501, at 9:30 A.M. on October 5, 2023, or as soon

          thereafter as counsel can be heard, for an Order: (1) pursuant to 3211(a)(7) and 3211(a)(8)

          dismissing the complaint, extension of time to answer and for such other and further relief as the

          Court deems just and proper and (2) for such other and further relief as this Court deems just and

          proper.


                    PLEASE TAKE FURTHER NOTICE that, pursuant to CPLR § 2214(b), answering

          papers, if any, must be served on the undersigned at least seven (7) day priors to the return date of

          this motion.




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FILED: NASSAU COUNTY CLERK 06/06/2023 04:03 PM                                INDEX NO. 607877/2023
NYSCEF DOC. NO. 6                                                       RECEIVED NYSCEF: 06/06/2023




          DATED:       June 6, 2023
                       Brooklyn, New York

                                                     DOMINICK DALE, ESQ


                                                 Dominick Dale Esq.
                                                 Attorney(s) for Defendant
                                                 81 Court Street
                                                 Brooklyn, NY 11201
                                                 (917) 816-8327


          To:   Lieberman and Klestzick
                Attorney(s) for Plaintiff
                71 South Central Avenue
                Valley Stream, NY 11580
                (516) 900-6720




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