On September 15, 2015 a
Motion,Ex Parte
was filed
involving a dispute between
Steven Cohn Esq As Receiver Of 985 Ocean Limited Liability Company,
and
Charles Neiss,
for Commercial
in the District Court of Nassau County.
Preview
(FILED: NASSAU COUNTY CLERK 0971572015 06:34 PM INDEX NO. 606026/2015
NYSCEF DOC. NO. 2 RECEIVED NYSCEF: 09/15/2015
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF NASSAU
See ee eee aS eayereverererere res x
STEVEN CORN, ESQ., as Receiver of 985 Ocean : Index No. /15
Limited Liability Company,
Plaintiff,
-against- NOTICE OF MOTION
: FOR SUMMARY
CHARLES NEISS, JUDGMENT IN LIEU
: OF COMPLAINT
Defendant.
sreetoh mG Set SACL ININNC RCRD ICR ERSOENRCNRCDNRSRIOS. ALOR SRS x
PLEASE TAKE NOTICE that upon the annexed Affidavit in Support of Motion for
Summary Judgment in Lieu of Complaint of Steven Cohn, Esq., sworn to on September 11, 2015,
and the exhibits annexed thereto and the Memorandum of Law dated September 15, 2015, plaintiff
Steven Cohn, Esq., as Receiver of 985 Ocean Limited Liability Company, shall move this Court at
the Courthouse located at 100 Supreme Court Drive, Mineola, NY on October 30, 2015 at 9:30 a.m.
or as soon thereafter as counsel can be heard, for an order pursuant to NY CPLR 3213 directing
entry of summary judgment for plaintiff and against defendant on a promissory note, dated April
1, 2009 in the principal amount of $18,7500.00 (the “Note”), with interest accrued thereon at the rate
set forth in the Note to the date of payment, together with the costs and disbursements of this action
and such other and further relief as the Court deems just and proper on the ground that this action
is based on an instrument for the payment of money only which is now due and payable to which
there are no defenses.PLEASE TAKE FURTHER NOTICE that, pursuant to NY CPLR 2214, opposing papers,
if any, must be served at least seven days before the return date of this motion.
Dated: September 15, 2015
To:
Charles Neiss
c/o Moshe Y. Katlowitz, Esq.
Katlowitz & Associates
ABRAMS, FENSTERMAN, FENSTERMAN, EISMAN,
FORMATO, FERRARA & WOLF, LLP
By:
Mittthew F. Didora
1111 Marcus Avenue, Suite 107
Lake Success, NY 11042
(516) 328-2300
Attorneys for plaintiff
270 Madison Ave., Suite 1203
New York, NY 10016
Document Filed Date
September 15, 2015
Case Filing Date
September 15, 2015
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(FILED: NASSAU COUNTY CLERK 0971572015 06:34 PM INDEX NO. 606026/2015 NYSCEF DOC. NO. 2 RECEIVED NYSCEF: 09/15/2015 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF NASSAU See ee eee aS eayereverererere res x STEVEN CORN, ESQ., as Receiver of 985 Ocean : Index No. /15 Limited Liability Company, Plaintiff, -against- NOTICE OF MOTION : FOR SUMMARY CHARLES NEISS, JUDGMENT IN LIEU : OF COMPLAINT Defendant. sreetoh mG Set SACL ININNC RCRD ICR ERSOENRCNRCDNRSRIOS. ALOR SRS x PLEASE TAKE NOTICE that upon the annexed Affidavit in Support of Motion for Summary Judgment in Lieu of Complaint of Steven Cohn, Esq., sworn to on September 11, 2015, and the exhibits annexed thereto and the Memorandum of Law dated September 15, 2015, plaintiff Steven Cohn, Esq., as Receiver of 985 Ocean Limited Liability Company, shall move this Court at the Courthouse located at 100 Supreme Court Drive, Mineola, NY on October 30, 2015 at 9:30 a.m. or as soon thereafter as counsel can be heard, for an order pursuant to NY CPLR 3213 directing entry of summary judgment for plaintiff and against defendant on a promissory note, dated April 1, 2009 in the principal amount of $18,7500.00 (the “Note”), with interest accrued thereon at the rate set forth in the Note to the date of payment, together with the costs and disbursements of this action and such other and further relief as the Court deems just and proper on the ground that this action is based on an instrument for the payment of money only which is now due and payable to which there are no defenses.PLEASE TAKE FURTHER NOTICE that, pursuant to NY CPLR 2214, opposing papers, if any, must be served at least seven days before the return date of this motion. Dated: September 15, 2015 To: Charles Neiss c/o Moshe Y. Katlowitz, Esq. Katlowitz & Associates ABRAMS, FENSTERMAN, FENSTERMAN, EISMAN, FORMATO, FERRARA & WOLF, LLP By: Mittthew F. Didora 1111 Marcus Avenue, Suite 107 Lake Success, NY 11042 (516) 328-2300 Attorneys for plaintiff 270 Madison Ave., Suite 1203 New York, NY 10016