Document for Kathleen Kammer, Patrick Lawrence Individually and as Resident Representative of Kathleen Kammer v. 185 Old Military Road Operating Company, Llc, 185 Old Military Road, Llc d/b/a ELDERWOOD OF UIHLEIN AT LAKE PLACID
On October 11, 2023 a
NOTICE OF MOTION
was filed
involving a dispute between
Kathleen Kammer,
Patrick Lawrence
Individually And As Resident Representative Of Kathleen Kammer,
and
185 Old Military Road, Llc
D B A Elderwood Of Uihlein At Lake Placid,
185 Old Military Road Operating Company, Llc,
for Torts - Other Negligence (Personal Injury)
in the District Court of Essex County.
Preview
FILED: ESSEX COUNTY CLERK 11/24/2023 04:34 PM INDEX NO. CV23-0490
NYSCEF DOC. NO. 6 RECEIVED NYSCEF: 11/24/2023
STATE OF NEW YORK
SUPREME COURT : COUNTY OF ESSEX
KATHLEEN KAMMER and PATRICK
LAWRENCE, Individually and as Resident
Representative of Kathleen Kammer,
Plaintiff, NOTICE OF MOTION
-against-
Index No. CV23-0490
185 OLD MILITARY ROAD OPERATING
COMPANY, LLC and 185 OLD MILITARY ROAD,
LLC, d/b/a ELDERWOOD OF UIHLEIN AT LAKE
PLACID,
Defendants.
PLEASE TAKE NOTICE that a motion will be made for the relief specified herein in
connection with the above-entitled action as follows:
MOTION MADE BY: 185 Old Military Road Operating Company, LLC and 185
Old Military Road, LLC, D/B/A Elderwood of Uihlein at
Lake Placid, LLC
DATE, TIME AND
PLACE OF HEARING: On the ____ day of ___________, 2023 at 10:00 a.m., or as
soon thereafter as counsel may be heard, at the
Supreme Court, Essex County Courthouse 7559 Court
Street, Elizabethtown, New York 12932.
RELIEF SOUGHT AND
GROUNDS THEREFOR: An Order pursuant to CPLR §3211(a) (5) and (7) dismissing
the Complaint in its entirety, together with such other and
further relief the Court may deem just and proper.
SUPPORTING PAPERS: Notice of Motion, Attorney Affirmation of Christina M.
Verone Juliano, Esq., with attached exhibits, Memorandum
of Law and prior pleadings and proceedings.
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FILED: ESSEX COUNTY CLERK 11/24/2023 04:34 PM INDEX NO. CV23-0490
NYSCEF DOC. NO. 6 RECEIVED NYSCEF: 11/24/2023
PLEASE TAKE FURTHER NOTICE that answering Affidavits and papers, if any,
must be served pursuant to CPLR §2214(b) and the Uniform Civil Rules.
Dated: Syracuse, New York
November 24, 2023
GOLDBERG SEGALLA LLP
______________________________
Christina M. Verone Juliano
Attorneys for Defendant Ballston Two, LLC
5786 Widewaters Parkway
Syracuse, New York 13202
Phone: 315-413-5425
TO: Edward B. Flink, Esq.
Flink Maswick Law PLLC
Attorneys for Plaintiffs
2577 Main Street
Lake Placid, NY 12946
(518) 523-2441
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Preview
FILED: ESSEX COUNTY CLERK 11/24/2023 04:34 PM INDEX NO. CV23-0490 NYSCEF DOC. NO. 6 RECEIVED NYSCEF: 11/24/2023 STATE OF NEW YORK SUPREME COURT : COUNTY OF ESSEX KATHLEEN KAMMER and PATRICK LAWRENCE, Individually and as Resident Representative of Kathleen Kammer, Plaintiff, NOTICE OF MOTION -against- Index No. CV23-0490 185 OLD MILITARY ROAD OPERATING COMPANY, LLC and 185 OLD MILITARY ROAD, LLC, d/b/a ELDERWOOD OF UIHLEIN AT LAKE PLACID, Defendants. PLEASE TAKE NOTICE that a motion will be made for the relief specified herein in connection with the above-entitled action as follows: MOTION MADE BY: 185 Old Military Road Operating Company, LLC and 185 Old Military Road, LLC, D/B/A Elderwood of Uihlein at Lake Placid, LLC DATE, TIME AND PLACE OF HEARING: On the ____ day of ___________, 2023 at 10:00 a.m., or as soon thereafter as counsel may be heard, at the Supreme Court, Essex County Courthouse 7559 Court Street, Elizabethtown, New York 12932. RELIEF SOUGHT AND GROUNDS THEREFOR: An Order pursuant to CPLR §3211(a) (5) and (7) dismissing the Complaint in its entirety, together with such other and further relief the Court may deem just and proper. SUPPORTING PAPERS: Notice of Motion, Attorney Affirmation of Christina M. Verone Juliano, Esq., with attached exhibits, Memorandum of Law and prior pleadings and proceedings. 1 38388760.v1 1 of 2 FILED: ESSEX COUNTY CLERK 11/24/2023 04:34 PM INDEX NO. CV23-0490 NYSCEF DOC. NO. 6 RECEIVED NYSCEF: 11/24/2023 PLEASE TAKE FURTHER NOTICE that answering Affidavits and papers, if any, must be served pursuant to CPLR §2214(b) and the Uniform Civil Rules. Dated: Syracuse, New York November 24, 2023 GOLDBERG SEGALLA LLP ______________________________ Christina M. Verone Juliano Attorneys for Defendant Ballston Two, LLC 5786 Widewaters Parkway Syracuse, New York 13202 Phone: 315-413-5425 TO: Edward B. Flink, Esq. Flink Maswick Law PLLC Attorneys for Plaintiffs 2577 Main Street Lake Placid, NY 12946 (518) 523-2441 2 38388760.v1 2 of 2