Summons: Paul Marino v. Jeffrey Arcello, Ac Design Property & Equipment Corp.

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                                FILED: RICHMOND COUNTY CLERK 03/26/2024 05:23 PM                                                  INDEX NO. 150609/2024
NYSCEF DOC. NO. 1                                                                          RECEIVED NYSCEF: 03/26/2024




         SUPREME COURT OF THE STATE OF NEW YORK
         COUNTY OF RICHMOND
         ---------------------------------------------------------------------X
         PAUL MARINO,
                                                                                  Index No.:
                                                 Plaintiff,

                    -against-                                                     SUMMONS

         JEFFREY ARCELLO and AC DESIGN PROPERTY &
         EQUIPMENT CORP.,

                                                  Defendants.
         ---------------------------------------------------------------------X

          TO THE ABOVE NAMED DEFENDANTS:

                 You are hereby summoned and required to submit to Plaintiffs’ attorney your answering

          papers on this motion within the time provided in the Notice of Motion annexed hereto. In case

          of your failure to submit answering papers, summary judgment will be taken against you by

          default for the relief demanded in the Notice of Motion.

          Dated: New York, New York
                 March 26, 2024
                                                                       TRAVIS LAW PLLC


                                                               By:

                                                                       Joseph A. DeBlase, Esq.
                                                                       Attorneys for Plaintiff Paul Marino
                                                                       40 Wall Street, Suite 2508
                                                                       New York, New York 10005
                                                                       Tel: (212) 248-2120




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FILED: RICHMOND COUNTY CLERK 03/26/2024 05:23 PM                                                   INDEX NO. 150609/2024
NYSCEF DOC. NO. 1                                                                            RECEIVED NYSCEF: 03/26/2024




           SUPREME COURT OF THE STATE OF NEW YORK
           COUNTY OF RICHMOND
           ---------------------------------------------------------------------X
           PAUL MARINO,
                                                                                    Index No.:
                                                   Plaintiff,

                         -against-                                                  NOTICE OF MOTION FOR
                                                                                    SUMMARY JUDGMENT
           JEFFREY ARCELLO and AC DESIGN PROPERTY &                                 IN LIEU OF A COMPLAINT
           EQUIPMENT CORP.,
                                                                                    Motion Seq. #001
                                                    Defendants.
           ---------------------------------------------------------------------X

                      PLEASE TAKE NOTICE, that upon the annexed Affirmation of Paul Marino, dated

          March 26, 2024, Memorandum of Law, dated March 26, 2024, together with the annexed

          exhibits and pleadings heretofore made herein, the undersigned attorney for plaintiff Paul

          Marino, will move this Court located at 26 Central Avenue, Staten Island, New York 10301,

          on the 24th day of April, 2024 at 9:30 a.m. or as soon thereafter as counsel can be heard for an

          Order:

              (i)        Pursuant to CPLR § 3213, granting summary judgment to plaintiff Paul Marino

                         (“Plaintiff”) against defendants Jeffrey Arcello and AC Design Property &

                         Equipment Corp. (collectively “Defendants”) in the sum of $258,165.42, plus

                         statutory interest and costs;

              (ii)       Legal expenses and reasonable attorneys’ fees; and

              (iii)      Granting such other and further relief as this court deems appropriate and proper.



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

          affidavits, if any, are required to be served upon the undersigned counsel for Plaintiff at least

          seven (7) days before the return date of this motion.




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FILED: RICHMOND COUNTY CLERK 03/26/2024 05:23 PM                          INDEX NO. 150609/2024
NYSCEF DOC. NO. 1                                                  RECEIVED NYSCEF: 03/26/2024




          Dated: New York, New York
                 March 26, 2024
                                               TRAVIS LAW PLLC


                                       By:

                                               Joseph A. DeBlase, Esq.
                                               Attorneys for Plaintiff Paul Marino
                                               40 Wall Street, Suite 2508
                                               New York, New York 10005
                                               Tel: (212) 284-2120




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