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  • Liberty Mutual Insurance Company v. Cindy M Bury Other Special Proceeding document preview
  • Liberty Mutual Insurance Company v. Cindy M Bury Other Special Proceeding document preview
  • Liberty Mutual Insurance Company v. Cindy M Bury Other Special Proceeding document preview
  • Liberty Mutual Insurance Company v. Cindy M Bury Other Special Proceeding document preview
						
                                

Preview

DU hk DIV INDEX NO. 2014-50977 UD OUN NYSCEF BOC. NO. 2 RECEIVED NYSCEF: 10/27/2014 LA275-024588792-0004 SN SPN:spn SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF DUTCHESS x In the Matter of the Application of LIBERTY MUTUAL INSURANCE COMPANY, Petitioner, NOTICE OF PETITION vs. INDEX No. Filed: To Stay the Arbitration sought to be had by CINDY M. BURY, Respondent. x PLEASE TAKE NOTICE, that upon the annexed affirmation of SAMI P. NASSER dated the 27" day of October , 2014, and upon all the pleadings and proceedings had herein, the undersigned will petition this court to be held in and for the County of Dutchess at the Courthouse located at 10 Market Street, Poughkeepsie, New York 12601 on the 10 day of December, 2014, at 9:30 a.m. or as soon thereafter as counsel can be heard for an order pursuant to CPLR 7503(c) Temporarily staying the Respondent(s) from proceeding to Arbitration against the Petitioner(s) and compelling Respondent to submit to an EUO, IME and provide paper discovery and to stay the arbitration of this matter until all discovery is complied with, and for such other and further relief’as this court deems just and proper. PLEASE TAKE FURTHER NOTICE that answering affidavits if any must be served upon the undersigned at least seven (7) days prior to the return date of this petition. Dated: White Plains, New York October 27,2014 Yours etc., BURKE, GORDON & CONWAY Attorneys for Petitioner LIBERTY MUTUAL INSURANCE COMPANY INC. 10 Bank Street ~ Suite 790 White Plains, NY 10606 (914) 997-8100 TO KRAVET, HOEFER & MAHER, P.C. ATTORNEYS FOR RESPONDENT CINDY M. BURY 1135A MORRIS PARK AVENUE, SUITE 202 BRONX, NEW YORK 10461 AMERICAN ARBITRATION ASSOCIATION 120 BROADWAY NEW YORK, NEW YORK 10006