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  • Hasupha Bryant v. Festival Fun Parks, Llc D/B/A Splish Splash Tort document preview
  • Hasupha Bryant v. Festival Fun Parks, Llc D/B/A Splish Splash Tort document preview
  • Hasupha Bryant v. Festival Fun Parks, Llc D/B/A Splish Splash Tort document preview
  • Hasupha Bryant v. Festival Fun Parks, Llc D/B/A Splish Splash Tort document preview
						
                                

Preview

INDEX NO. 604240/2014 NYSCEF DOC. NO. 13 RECEIVED NYSCEF: 06/05/2015 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF NASSAU HASUPHA BRYANT, Index No.: 604240/14 Plaintiff, NOTICE OF MOTION - against — FESTIVAL FUN PARKS, LLC d/b/a SPLISH SPLASH, Defendant. PLEASE TAKE NOTICE, that upon the annexed affirmation of Stephanie S. Matar, Esq., dated June 1, 2015, and the exhibits annexed thereto, the undersigned will move this Court at the Motion Support Office, Room 186 of the Supreme Court of the State of New York, County of Nassau located at the Supreme Court Building, 100 Supreme Court Drive, Room 186, Mineola, New York at 9:30 a.m., on the 25% day of June, 2015, or as soon thereafter as counsel can be heard for an Order: (1) pursuant to New York Civil Practice Law and Rules (“CPLR”) § 3126, dismissing plaintiff's Verified Complaint, or in the alternative, (2) pursuant to CPLR 3124, compelling plaintiff to provide the Court-Ordered discovery by a date certain to be set down by this Court or be precluded from offering such evidence at the time of trial; and (3) granting such other and further relief as this Honorable Court deems just and proper.PLEASE TAKE FURTHER NOTICE that answering papers, if any, must be served within seven (7) days prior to the return date of this motion. Dated: New York, New York June 1, 2015 Sincerely, HAVKINS ROSENFELD RITZERT & VARRIALE, LLP By: AAA “Step! nie S. Matar, Esq. Attorneys for Defendant FESTIVAL FUN PARKS, LLC 1065 Avenue of the Americas, Suite 800 New York, New York 10018 (212) 488-1598 File No.: 3368-94 TO: THE LAW OFFICES OF ALAN M. SANDERS, LLC Attorneys for Plaintiff One Old Country Road, Suite 320 Carle Place, New York 11514 (516) 742-6400