On August 15, 2023 a
Motion,Ex Parte
was filed
involving a dispute between
Marcel Mukhamedov,
and
Dhaneshwar Balkaran,
for Torts - Motor Vehicle
in the District Court of Queens County.
Preview
FILED: QUEENS COUNTY CLERK 01/18/2024 02:29 PM INDEX NO. 716946/2023
NYSCEF DOC. NO. 5 RECEIVED NYSCEF: 01/18/2024
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF QUEENS
MARCEL MUKHAMEDOV,
Plaintiff, NOTICE OF MOTION
-against-
Index No: 716946/2023
DHANESHWAR BALKARAN,
Defendant.
SIRS:
PLEASE TAKE NOTICE, that upon the annexed affirmation of Melanie Abrams, Esq.,
dated January 18, 2024 and all the pleadings, proceedings and exhibits heretofore had herein, the
undersigned will move this Court at a Motion Part of the Queens County Courthouse located at
88-11 Sutphin Blvd, Jamaica, NY 11435, before an Honorable Justice of the Court on the 25 day
of Wanat Jo44, at 9:30 a.m., or in the forenoon of that day or as soon thereafter as counsel can
be heard for the following relief:
An Order, pursuant to CPLR §3215, directing that a default judgment be entered against the
Defendant, DHANESHWAR BALKARAN, or, in the alternative, setting this matter down for an
inquest in favor of the Plaintiff, assessing damages in a sum certain or for a sum which can, by
attorneys'
computation, be made certain, awarding costs, fees and sanctions to Plaintiff's attorneys,
and for such other and further relief which to this Court seems just and proper.
PLEASE TAKE FURTHER NOTICE, that pursuant to Rule 2214(b) of the CPLR, you are
required to serve upon the undersigned at least seven days prior to the return date of the instant
Motion, all answering affidavits and other papers to be used in opposition thereto.
ABRAMS LAW GROUP, P.C.
1 of 2
FILED: QUEENS COUNTY CLERK 01/18/2024 02:29 PM INDEX NO. 716946/2023
NYSCEF DOC. NO. 5 RECEIVED NYSCEF: 01/18/2024
Dated: Forest Hills, New York
January 18, 2024
Yours, etc.
By: Melanie Abrams, Esq.
ABRAMS LAW GROUP, P.C.
Attorneys for Plaintiff
MARCEL MUKHAMEDOV
104-70 Queens Boulevard, Suite 502
Forest Hills, NY 11375
(718) 997-9700
TO:
DHANESHWAR BALKARAN
Pro-Se Defendant
108-52 LIVERPOOL STREET
JAMAICA, NY 11435
ABRAMS LAW GROUP, P.C.
2 of 2
Document Filed Date
January 18, 2024
Case Filing Date
August 15, 2023
Category
Torts - Motor Vehicle
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Preview
FILED: QUEENS COUNTY CLERK 01/18/2024 02:29 PM INDEX NO. 716946/2023 NYSCEF DOC. NO. 5 RECEIVED NYSCEF: 01/18/2024 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF QUEENS MARCEL MUKHAMEDOV, Plaintiff, NOTICE OF MOTION -against- Index No: 716946/2023 DHANESHWAR BALKARAN, Defendant. SIRS: PLEASE TAKE NOTICE, that upon the annexed affirmation of Melanie Abrams, Esq., dated January 18, 2024 and all the pleadings, proceedings and exhibits heretofore had herein, the undersigned will move this Court at a Motion Part of the Queens County Courthouse located at 88-11 Sutphin Blvd, Jamaica, NY 11435, before an Honorable Justice of the Court on the 25 day of Wanat Jo44, at 9:30 a.m., or in the forenoon of that day or as soon thereafter as counsel can be heard for the following relief: An Order, pursuant to CPLR §3215, directing that a default judgment be entered against the Defendant, DHANESHWAR BALKARAN, or, in the alternative, setting this matter down for an inquest in favor of the Plaintiff, assessing damages in a sum certain or for a sum which can, by attorneys' computation, be made certain, awarding costs, fees and sanctions to Plaintiff's attorneys, and for such other and further relief which to this Court seems just and proper. PLEASE TAKE FURTHER NOTICE, that pursuant to Rule 2214(b) of the CPLR, you are required to serve upon the undersigned at least seven days prior to the return date of the instant Motion, all answering affidavits and other papers to be used in opposition thereto. ABRAMS LAW GROUP, P.C. 1 of 2 FILED: QUEENS COUNTY CLERK 01/18/2024 02:29 PM INDEX NO. 716946/2023 NYSCEF DOC. NO. 5 RECEIVED NYSCEF: 01/18/2024 Dated: Forest Hills, New York January 18, 2024 Yours, etc. By: Melanie Abrams, Esq. ABRAMS LAW GROUP, P.C. Attorneys for Plaintiff MARCEL MUKHAMEDOV 104-70 Queens Boulevard, Suite 502 Forest Hills, NY 11375 (718) 997-9700 TO: DHANESHWAR BALKARAN Pro-Se Defendant 108-52 LIVERPOOL STREET JAMAICA, NY 11435 ABRAMS LAW GROUP, P.C. 2 of 2