On February 25, 2014 a
Motion-Secondary
was filed
involving a dispute between
Thora Claudette Challenger,
and
Charles S Giles,
George J Lamadeleine,
J.B. Hunt Transport, Inc.,,
Zephaniah P Mullin,
for Tort
in the District Court of New York County.
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INDEX NO. 151998/2014
FILED: NEW YORK COUNTY CLERK 08/28/2017 08:31 AM
NYSCEF DOC. NO. 119 RECEIVED NYSCEF 08/28/2017
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF NEW YORK
THORA CLAUDETTE CHALLENGER, AFFIRMATION
IN SUPPORT
Plaintiff,
Index No.:151998/14
-against-
GEORGE J. LAMADELEINE, J. B. HUNT TRANSPORT,
INC., ZEPHANIAH P. MULLIN, and CHARLES S. GILES,
Defendants.
Richard E. Noll, an attorney duly admitted to practice before the courts of this State, and
member of The Noll Law Firm, P.C., attorneys for Defendants, ZEPHANIAH P. MULLIN, and
CHARLES S. GILES, affirms the following to be true under penalty of perjury:
1 I am fully familiar with all of the pleadings and proceedings had in this matter previously,
and make this affirmation in support of the motion by Defendants GEORGE J.
LAMADELEINE and J. B. HUNT TRANSPORT, INC., seeking an Order to vacate to
Court Orders of the Honorable Paul A. Goetz dated February 6, 2017 and June 19, 2017;
vacate the Note of Issue and Certificate of Readiness; compel plaintiff to provide all
outstanding discovery; and extend the defendant's time to move for Summary Judgement;
currently returnable on September 05, 2017.
The procedural history set forth by the co-defendant is correct, and will not be reiterated
herein.
l incorporate the arguments made by movant without reiterating the same herein.
WHEREFORE, affirmant respectfully requests that the within motion be decided in
accordance with the above together with such other, further, and different relief as to this Court
seems just and proper.
1 of 2
: INDEX NO. 151998/2014
NYSCEF DOC. NO. 119 RECEIVED NYSCEF: 08/28/2017
DATED: SYOSSET, NEW YORK
(4
August 22, 2017
Ricl dE. Noll
Tye Noll Law Firm, P.C.
ttorneys for Defendants —
Zephaniah P. Mullin and Charles S. Giles
33 Queens Street, Suite 102
Syosset, New York 11791
(516) 307-1199
2 of 2
Document Filed Date
August 28, 2017
Case Filing Date
February 25, 2014
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INDEX NO. 151998/2014 FILED: NEW YORK COUNTY CLERK 08/28/2017 08:31 AM NYSCEF DOC. NO. 119 RECEIVED NYSCEF 08/28/2017 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF NEW YORK THORA CLAUDETTE CHALLENGER, AFFIRMATION IN SUPPORT Plaintiff, Index No.:151998/14 -against- GEORGE J. LAMADELEINE, J. B. HUNT TRANSPORT, INC., ZEPHANIAH P. MULLIN, and CHARLES S. GILES, Defendants. Richard E. Noll, an attorney duly admitted to practice before the courts of this State, and member of The Noll Law Firm, P.C., attorneys for Defendants, ZEPHANIAH P. MULLIN, and CHARLES S. GILES, affirms the following to be true under penalty of perjury: 1 I am fully familiar with all of the pleadings and proceedings had in this matter previously, and make this affirmation in support of the motion by Defendants GEORGE J. LAMADELEINE and J. B. HUNT TRANSPORT, INC., seeking an Order to vacate to Court Orders of the Honorable Paul A. Goetz dated February 6, 2017 and June 19, 2017; vacate the Note of Issue and Certificate of Readiness; compel plaintiff to provide all outstanding discovery; and extend the defendant's time to move for Summary Judgement; currently returnable on September 05, 2017. The procedural history set forth by the co-defendant is correct, and will not be reiterated herein. l incorporate the arguments made by movant without reiterating the same herein. WHEREFORE, affirmant respectfully requests that the within motion be decided in accordance with the above together with such other, further, and different relief as to this Court seems just and proper. 1 of 2 : INDEX NO. 151998/2014 NYSCEF DOC. NO. 119 RECEIVED NYSCEF: 08/28/2017 DATED: SYOSSET, NEW YORK (4 August 22, 2017 Ricl dE. Noll Tye Noll Law Firm, P.C. ttorneys for Defendants — Zephaniah P. Mullin and Charles S. Giles 33 Queens Street, Suite 102 Syosset, New York 11791 (516) 307-1199 2 of 2