On December 08, 2023 a
Motion,Ex Parte
was filed
involving a dispute between
Daniel Peckman,
Guisela Peckman,
and
Ted Mozes, Pllc,
for Commercial - Other (Domestication of Judgment)
in the District Court of Rockland County.
Preview
FILED: ROCKLAND COUNTY CLERK 12/08/2023 01:53 PM INDEX NO. 036350/2023
NYSCEF DOC. NO. 2 RECEIVED NYSCEF: 12/08/2023
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF ROCKLAND
------------------------------------------------------------------------x
DANIEL PECKMAN and GUISELA PECKMAN, :
: Index No.
Plaintiffs, :
: NOTICE OF MOTION FOR
v. : SUMMARY JUDGMENT IN
: LIEU OF COMPLAINT
TED MOZES, PLLC, :
: Motion Seq. No. 001
Defendant. :
------------------------------------------------------------------------x
PLEASE TAKE NOTICE, that upon a summons, the affidavit of Daniel Peckman, the
Affidavit of Marko Cerenko, Esq., the affirmation of Kevin Fritz, Esq., the memorandum of law,
plaintiffs Daniel Peckman and Guisela Peckman (collectively, “Plaintiffs”) will move in the
Supreme Court of the State of New York, County of Rockland, Room 130, at the Courthouse
located at 1 South Main Street, New City, NY 10956, on February 15, 2024, at 9:30 a.m., or as
soon thereafter as counsel can be heard, for an Order: (a) pursuant to CPLR § 3213, granting
Plaintiffs summary judgment in lieu of complaint to domesticate a judgment obtained against
defendant Ted Mozes, PLLC (“Defendant” or the “Escrow Agent”) in the State of Florida; said
summary judgment to: (i) direct Defendant to release a $145,000 deposit held, in escrow, to
Plaintiffs; and (ii) award Plaintiffs their reasonable attorneys’ fees, costs and expenses incurred in
connection therewith; and (b) awarding Plaintiffs all such other relief as the Court deems just and
proper.
PLEASE TAKE FURTHER NOTICE, that pursuant to CPLR § 3213, answering papers or
affidavits shall be served to be received by the undersigned ten (10) days prior to the return date
of this motion.
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1 of 2
FILED: ROCKLAND COUNTY CLERK 12/08/2023 01:53 PM INDEX NO. 036350/2023
NYSCEF DOC. NO. 2 RECEIVED NYSCEF: 12/08/2023
Dated: New York, NY MEISTER SEELIG & FEIN PLLC
December 8, 2023
By: /s/ Kevin Fritz
Kevin Fritz, Esq.
125 Park Avenue, 7th Floor
New York, NY 10017
Tel: (212) 655-3500
Attorneys for Plaintiffs
2
2 of 2
Document Filed Date
December 08, 2023
Case Filing Date
December 08, 2023
Category
Commercial - Other (Domestication of Judgment)
Status
Active-Post Judgment
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Preview
FILED: ROCKLAND COUNTY CLERK 12/08/2023 01:53 PM INDEX NO. 036350/2023 NYSCEF DOC. NO. 2 RECEIVED NYSCEF: 12/08/2023 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF ROCKLAND ------------------------------------------------------------------------x DANIEL PECKMAN and GUISELA PECKMAN, : : Index No. Plaintiffs, : : NOTICE OF MOTION FOR v. : SUMMARY JUDGMENT IN : LIEU OF COMPLAINT TED MOZES, PLLC, : : Motion Seq. No. 001 Defendant. : ------------------------------------------------------------------------x PLEASE TAKE NOTICE, that upon a summons, the affidavit of Daniel Peckman, the Affidavit of Marko Cerenko, Esq., the affirmation of Kevin Fritz, Esq., the memorandum of law, plaintiffs Daniel Peckman and Guisela Peckman (collectively, “Plaintiffs”) will move in the Supreme Court of the State of New York, County of Rockland, Room 130, at the Courthouse located at 1 South Main Street, New City, NY 10956, on February 15, 2024, at 9:30 a.m., or as soon thereafter as counsel can be heard, for an Order: (a) pursuant to CPLR § 3213, granting Plaintiffs summary judgment in lieu of complaint to domesticate a judgment obtained against defendant Ted Mozes, PLLC (“Defendant” or the “Escrow Agent”) in the State of Florida; said summary judgment to: (i) direct Defendant to release a $145,000 deposit held, in escrow, to Plaintiffs; and (ii) award Plaintiffs their reasonable attorneys’ fees, costs and expenses incurred in connection therewith; and (b) awarding Plaintiffs all such other relief as the Court deems just and proper. PLEASE TAKE FURTHER NOTICE, that pursuant to CPLR § 3213, answering papers or affidavits shall be served to be received by the undersigned ten (10) days prior to the return date of this motion. 1 1 of 2 FILED: ROCKLAND COUNTY CLERK 12/08/2023 01:53 PM INDEX NO. 036350/2023 NYSCEF DOC. NO. 2 RECEIVED NYSCEF: 12/08/2023 Dated: New York, NY MEISTER SEELIG & FEIN PLLC December 8, 2023 By: /s/ Kevin Fritz Kevin Fritz, Esq. 125 Park Avenue, 7th Floor New York, NY 10017 Tel: (212) 655-3500 Attorneys for Plaintiffs 2 2 of 2