On June 30, 2016 a
Motion,Ex Parte
was filed
involving a dispute between
Maria Urena,
and
Jp Morgan Chase,
Melissa Mathey,
Sherri Fitzgerald,
William Berdini,
William Li,
for Commercial - Other (employment discrimination)
in the District Court of Kings County.
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FILED: KINGS COUNTY CLERK 07/17/2018 11:14 PM INDEX NO. 511145/2016
NYSCEF DOC. NO. 86 RECEIVED NYSCEF: 07/17/2018
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF KINGS
-------------------------------------------------------------------x
:
MARIA URENA, :
:
Plaintiff, : Index No. 511145/2016
:
-against- :
:
JP MORGAN CHASE, :
NOTICE OF MOTION
WILLIAM LI, FOR SUMMARY JUDGMENT
MELISSA MATHEY,
SHERRI FITZJARRALD, and
WILLIAM BERDINI,
.
Defendants.
-------------------------------------------------------------------x
PLEASE TAKE NOTICE that, upon the Affirmation of Daniel M. Bernstein, dated July
17, 2018, and the exhibits annexed thereto, and the accompanying Memorandum of Law,
Defendants JP Morgan Chase, N.A., William Li, Melissa Mathey, Sherri Fitzjarrald, and William
"Defendants"
Berdini (collectively "Defendants") will move this Court, at the Supreme Court, County of
Kings, located at Jury Coordinating Part I, 360 Adams Street, Brooklyn, New York 11201 on
August 8, 2018, at 9:30 a.m., or as soon thereafter as counsel can be heard, for an order granting
Defendants'
Motion for Summary Judgment pursuant to CPLR § 3212 and dismissing Plaintiff's
Amended Verified Complaint with prejudice, and awarding to Defendants such other and further
relief as the Court deems just and appropriate.
1 of 2
FILED: KINGS COUNTY CLERK 07/17/2018 11:14 PM INDEX NO. 511145/2016
NYSCEF DOC. NO. 86 RECEIVED NYSCEF: 07/17/2018
PLEASE TAKE FURTHER NOTICE that pursuant to CPLR 2214(b), answering
papers, if any, must be served at least seven (7) days before the return date of this motion,
whereupon any reply papers shall be served at least one (1) day before the return date of this
motion. Defendants request oral argument.
Dated: New York, New York
July 17, 2018
Respectfully submitted,
OGLETREE, DEAKINS, NASH, SMOAK &
STEWART, P.C.
By: /s/ Daniel M. Bernstein
Daniel Bernstein
Patrick M. Collins
17th
599 Lexington Avenue, FlOOr
New York, NY 10022
Tel.: (212) 492-2500
Attorneys for Defendants
34880519.1
2 of 2
Document Filed Date
July 17, 2018
Case Filing Date
June 30, 2016
Category
Commercial - Other (employment discrimination)
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FILED: KINGS COUNTY CLERK 07/17/2018 11:14 PM INDEX NO. 511145/2016 NYSCEF DOC. NO. 86 RECEIVED NYSCEF: 07/17/2018 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF KINGS -------------------------------------------------------------------x : MARIA URENA, : : Plaintiff, : Index No. 511145/2016 : -against- : : JP MORGAN CHASE, : NOTICE OF MOTION WILLIAM LI, FOR SUMMARY JUDGMENT MELISSA MATHEY, SHERRI FITZJARRALD, and WILLIAM BERDINI, . Defendants. -------------------------------------------------------------------x PLEASE TAKE NOTICE that, upon the Affirmation of Daniel M. Bernstein, dated July 17, 2018, and the exhibits annexed thereto, and the accompanying Memorandum of Law, Defendants JP Morgan Chase, N.A., William Li, Melissa Mathey, Sherri Fitzjarrald, and William "Defendants" Berdini (collectively "Defendants") will move this Court, at the Supreme Court, County of Kings, located at Jury Coordinating Part I, 360 Adams Street, Brooklyn, New York 11201 on August 8, 2018, at 9:30 a.m., or as soon thereafter as counsel can be heard, for an order granting Defendants' Motion for Summary Judgment pursuant to CPLR § 3212 and dismissing Plaintiff's Amended Verified Complaint with prejudice, and awarding to Defendants such other and further relief as the Court deems just and appropriate. 1 of 2 FILED: KINGS COUNTY CLERK 07/17/2018 11:14 PM INDEX NO. 511145/2016 NYSCEF DOC. NO. 86 RECEIVED NYSCEF: 07/17/2018 PLEASE TAKE FURTHER NOTICE that pursuant to CPLR 2214(b), answering papers, if any, must be served at least seven (7) days before the return date of this motion, whereupon any reply papers shall be served at least one (1) day before the return date of this motion. Defendants request oral argument. Dated: New York, New York July 17, 2018 Respectfully submitted, OGLETREE, DEAKINS, NASH, SMOAK & STEWART, P.C. By: /s/ Daniel M. Bernstein Daniel Bernstein Patrick M. Collins 17th 599 Lexington Avenue, FlOOr New York, NY 10022 Tel.: (212) 492-2500 Attorneys for Defendants 34880519.1 2 of 2