On September 12, 2023 a
NOTICE OF MOTION
was filed
involving a dispute between
Natasha Valentin Cepeda,
and
Elizabeth T. Churchill,
Stephen K Churchill,
for Torts - Motor Vehicle
in the District Court of Queens County.
Preview
FILED: QUEENS COUNTY CLERK 10/10/2023 05:11 PM INDEX NO. 718856/2023
NYSCEF DOC. NO. 8 RECEIVED NYSCEF: 10/10/2023
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF QUEENS
------------------------------------------------------------------X Index No.: 718856/2023
NATASHA VALENTIN CEPEDA,
Plaintiff
-against- NOTICE OF MOTION
ELIZABETH T. CHURCHILL
and STEPHEN K CHURCHILL
Defendant.
____________________________________________________________________Ç
PLEASE TAKE NOTICE, that upon the affirmation of Nicholas Gonchar, Esq., and upon
all the pleadings and proceedings heretofore had herein, and the exhibits attached hereto, the
Plaintiff, will move this Court before an I.A.S. Motion Part at the Supreme Court QUEENS County
31"
Courthouse, 88-11 Sutphin Blvd. Jamaica, NY 11435 on the day of October 2023 at 9:30
o'clock in the forenoon of that day or as soon thereafter as counsel can be heard for an Order: (1)
Granting a Default Judgment against Defendants ELIZABETH T. CHURCHILL AND STEPHEN
K CHURCHILL, for failure to answer the complaint within the time permitted by law; (2) setting
this matter down for an Inquest at time of trial on damages only; and (3) for such other, further
and different relief as to this Honorable Court may deem just and proper.
PLEASE TAKE FURTHER NOTICE that pursuant to CPLR 2214 (b), answering
affidavits, if any, are to be served upon the undersigned no later than seven (7) days prior to the
return date of this motion.
Dated: New York, New York Yours, etc.
October 10, 2023
(B : Nicholas Gonchar, Esq.
KRENTSEL GUZMAN HERBERT, LLP.
Attorneys for Plaintiff(s)
17 Battery Place - Suite 604
New York, New York 10004
1 of 3
FILED: QUEENS COUNTY CLERK 10/10/2023 05:11 PM INDEX NO. 718856/2023
NYSCEF DOC. NO. 8 RECEIVED NYSCEF: 10/10/2023
TO:
ELIZABETH T. CHURCHILL
145 Oakdene Ave
Leonia, NJ 07605
STEPHEN K CHURCHILL
145 Oakdene Ave
Leonia, NJ 07605
2 of 3
FILED: QUEENS COUNTY CLERK 10/10/2023 05:11 PM INDEX NO. 718856/2023
NYSCEF DOC. NO. 8 RECEIVED NYSCEF: 10/10/2023
Index No.: 718856/2023
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF QUEENS
NATASHA VALENTIN CEPEDA,
Plaintiff,
-against-
ELIZABETH T. CHURCHILL and
STEPHEN K CHURCHILL
Defendants.
NOTICE OF MOTION, AFFIRMATION IN SUPPORT, RR
KRENTSEL GUZMAN HERBERT, LLP.
Attorneys for : Plaintiff(s)
Office and Post Office Address, Telephone
17 Battery Place, #604
New York, New York 10004
(212) 227-2900
3 of 3
Document Filed Date
October 10, 2023
Case Filing Date
September 12, 2023
Category
Torts - Motor Vehicle
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Preview
FILED: QUEENS COUNTY CLERK 10/10/2023 05:11 PM INDEX NO. 718856/2023 NYSCEF DOC. NO. 8 RECEIVED NYSCEF: 10/10/2023 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF QUEENS ------------------------------------------------------------------X Index No.: 718856/2023 NATASHA VALENTIN CEPEDA, Plaintiff -against- NOTICE OF MOTION ELIZABETH T. CHURCHILL and STEPHEN K CHURCHILL Defendant. ____________________________________________________________________Ç PLEASE TAKE NOTICE, that upon the affirmation of Nicholas Gonchar, Esq., and upon all the pleadings and proceedings heretofore had herein, and the exhibits attached hereto, the Plaintiff, will move this Court before an I.A.S. Motion Part at the Supreme Court QUEENS County 31" Courthouse, 88-11 Sutphin Blvd. Jamaica, NY 11435 on the day of October 2023 at 9:30 o'clock in the forenoon of that day or as soon thereafter as counsel can be heard for an Order: (1) Granting a Default Judgment against Defendants ELIZABETH T. CHURCHILL AND STEPHEN K CHURCHILL, for failure to answer the complaint within the time permitted by law; (2) setting this matter down for an Inquest at time of trial on damages only; and (3) for such other, further and different relief as to this Honorable Court may deem just and proper. PLEASE TAKE FURTHER NOTICE that pursuant to CPLR 2214 (b), answering affidavits, if any, are to be served upon the undersigned no later than seven (7) days prior to the return date of this motion. Dated: New York, New York Yours, etc. October 10, 2023 (B : Nicholas Gonchar, Esq. KRENTSEL GUZMAN HERBERT, LLP. Attorneys for Plaintiff(s) 17 Battery Place - Suite 604 New York, New York 10004 1 of 3 FILED: QUEENS COUNTY CLERK 10/10/2023 05:11 PM INDEX NO. 718856/2023 NYSCEF DOC. NO. 8 RECEIVED NYSCEF: 10/10/2023 TO: ELIZABETH T. CHURCHILL 145 Oakdene Ave Leonia, NJ 07605 STEPHEN K CHURCHILL 145 Oakdene Ave Leonia, NJ 07605 2 of 3 FILED: QUEENS COUNTY CLERK 10/10/2023 05:11 PM INDEX NO. 718856/2023 NYSCEF DOC. NO. 8 RECEIVED NYSCEF: 10/10/2023 Index No.: 718856/2023 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF QUEENS NATASHA VALENTIN CEPEDA, Plaintiff, -against- ELIZABETH T. CHURCHILL and STEPHEN K CHURCHILL Defendants. NOTICE OF MOTION, AFFIRMATION IN SUPPORT, RR KRENTSEL GUZMAN HERBERT, LLP. Attorneys for : Plaintiff(s) Office and Post Office Address, Telephone 17 Battery Place, #604 New York, New York 10004 (212) 227-2900 3 of 3