On June 30, 2015 a
Motion,Ex Parte
was filed
involving a dispute between
Partners In Safety Inc.,
and
Cardworks Acquiring Llc,
Merrick Bank Corporation,
for Commercial
in the District Court of Nassau County.
Preview
(FILED: NASSAU COUNTY CLERK 08717/2015 12:41 PM INDEX NO. 604244/2015
NYSCEF DOC. NO. 3 RECEIVED NYSCEF: 08/17/2015
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF NASSAU
weve cece nee ee eeeeeeeeeeeeeeeeseeeeee x
PARTNERS IN SAFETY INC.,
Plaintiff, : Index No.: 604244/2015
-against- : NOTICE OF MOTION
CARDWORKS ACQUIRING LLC and :
MERRICK BANK CORPORATION,
Defendants.
wee eee eee cee eee eee eee ence x
COUNSELOR:
PLEASE TAKE NOTICE that, upon the annexed Affidavit of Russell Berman, sworn to
August 13, 2015, with exhibits annexed thereto, the annexed Affidavit of Michael H. Gibson,
sworn to August 14, 2015, with exhibits annexed thereto, and the accompanying Memorandum
of Law, dated August 14, 2015; Defendants CardWorks Acquiring LLC and Merrick Bank
Corporation will move before an I.A.S. Part of the Supreme Court of the State of New York,
County of Nassau, located at 100 Supreme Court Drive, Mineola, New York, on September 11,
2015 at 9:30 am, for an order, pursuant to CPLR § 321 1(a)(1): (i) dismissing this action in its
entirety; (ii) awarding the Defendants recovery of their costs associated with this action,
including reasonable attorneys’ fees; and (iii) awarding the Defendants such further relief as this
Court deems just and proper.
PLEASE TAKE FURTHER NOTICE that, pursuant to CPLR § 2214(b), opposition to
this motion must be served no later than seven (7) days prior to the return date of the motion.
2275696_1Dated: August 14, 2015
SATTERLEE STEPHENS BURKE
& BURKE LLP ~
3
z
By: Daniel G. Gurfein
Michael H. Gibson
Attorneys for Defendants
230 Park Avenue, Suite 1130
New York, New York 10169
(212) 818-9200
2275696_1
Document Filed Date
August 17, 2015
Case Filing Date
June 30, 2015
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(FILED: NASSAU COUNTY CLERK 08717/2015 12:41 PM INDEX NO. 604244/2015 NYSCEF DOC. NO. 3 RECEIVED NYSCEF: 08/17/2015 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF NASSAU weve cece nee ee eeeeeeeeeeeeeeeeseeeeee x PARTNERS IN SAFETY INC., Plaintiff, : Index No.: 604244/2015 -against- : NOTICE OF MOTION CARDWORKS ACQUIRING LLC and : MERRICK BANK CORPORATION, Defendants. wee eee eee cee eee eee eee ence x COUNSELOR: PLEASE TAKE NOTICE that, upon the annexed Affidavit of Russell Berman, sworn to August 13, 2015, with exhibits annexed thereto, the annexed Affidavit of Michael H. Gibson, sworn to August 14, 2015, with exhibits annexed thereto, and the accompanying Memorandum of Law, dated August 14, 2015; Defendants CardWorks Acquiring LLC and Merrick Bank Corporation will move before an I.A.S. Part of the Supreme Court of the State of New York, County of Nassau, located at 100 Supreme Court Drive, Mineola, New York, on September 11, 2015 at 9:30 am, for an order, pursuant to CPLR § 321 1(a)(1): (i) dismissing this action in its entirety; (ii) awarding the Defendants recovery of their costs associated with this action, including reasonable attorneys’ fees; and (iii) awarding the Defendants such further relief as this Court deems just and proper. PLEASE TAKE FURTHER NOTICE that, pursuant to CPLR § 2214(b), opposition to this motion must be served no later than seven (7) days prior to the return date of the motion. 2275696_1Dated: August 14, 2015 SATTERLEE STEPHENS BURKE & BURKE LLP ~ 3 z By: Daniel G. Gurfein Michael H. Gibson Attorneys for Defendants 230 Park Avenue, Suite 1130 New York, New York 10169 (212) 818-9200 2275696_1