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NYSCEF DOC. NO. 12
TMS/Id_ #14078
MOTION BY:
DATE, TIME AND
RELIEF REQUESTED:
SUPREME COURT OF THE STATE OF NEW YORK
ASSOCIATES, LLC, PROTO PROPERTY SERVICES,
LLC, and CPC RESOURCES, INC.,
Defendants.
PLACE RETURNABLE:
INDEX NO. 508318/2013
RECEIVED NYSCEF: 10/02/2014
COUNTY OF KINGS
penne nent enn enn nent nme OEY xX Index No.: 508318/2013
VIRGINIA BOND,
NOTICE OF MOTION
-against- Return Date: October 24, 2014
| Refer To: Central Compliance |
RIVERDALE OSBORNE TOWERS HOUSING Part
KERLEY, WALSH, MATERA
& CINQUEMANI, P.C.
Attorneys for Defendants, RIVERDALE OSBORNE
TOWERS HOUSING ASSOC. LLC and PROTO
PROPERTY SERVICES, LLC
On the 24" day of October at 9:30 in the
forenoon of that day, at the Supreme Court, Kings
County, 360 Adams Street, Brooklyn, New York
11201, or as soon thereafter as counsel can be heard.
An Order of the Court pursuant to CPLR §3042 and
CPLR §3126, dismissing the plaintiff's Complaint; or,
in the alternative, precluding plaintiff in offering any
evidence at the time of trial relative to those items
contained in the discovery demands to whichSUPPORTING PAPERS:
ANSWERING PAPERS:
Dated: Seaford, New York
October 2, 2014
plaintiffs counsel has not yet provided responses; or,
in the alternative, pursuant to CPLR Rule 3124,
compelling plaintiff to provide all discovery responses
by a date certain, with a conditional order of
dismissal, along with such other and further relief as
this Court deems just, proper and equitable.
Affirmation of Timothy M. Shelley, Esq., and all
other pleadings and proceedings heretofore had
herein, and all exhibits annexed hereto and made a
part hereof.
Answering affirmation or affidavits, if any, must be
served upon the undersigned attorneys at least seven
(7) days prior to the return date of this motion
pursuant to Rule 2214 of the CPLR.
Yours, etc.,
KERLEY, WALSH, MATERA
& CINQUEMAN|, P.C.
By:
TIMOTHY M.SHELDEY, ESQ.
Attorneys for Defendant /
RIVERDALE OSBORNE TOWERS HOUSING ASSOC.
LLC and PROTO PROPERTY SERVICES, LLC
2174 Jackson Avenue
Seaford, New York 11783
(516) 409-6200TO:
MARC E. SEITELMAN LAW OFFICES, P.C.
Attorney for Plaintiff
111 Broadway, 9" Floor
New York, NY 10006
(212) 962-2626
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NYSCEF DOC. NO. 12 TMS/Id_ #14078 MOTION BY: DATE, TIME AND RELIEF REQUESTED: SUPREME COURT OF THE STATE OF NEW YORK ASSOCIATES, LLC, PROTO PROPERTY SERVICES, LLC, and CPC RESOURCES, INC., Defendants. PLACE RETURNABLE: INDEX NO. 508318/2013 RECEIVED NYSCEF: 10/02/2014 COUNTY OF KINGS penne nent enn enn nent nme OEY xX Index No.: 508318/2013 VIRGINIA BOND, NOTICE OF MOTION -against- Return Date: October 24, 2014 | Refer To: Central Compliance | RIVERDALE OSBORNE TOWERS HOUSING Part KERLEY, WALSH, MATERA & CINQUEMANI, P.C. Attorneys for Defendants, RIVERDALE OSBORNE TOWERS HOUSING ASSOC. LLC and PROTO PROPERTY SERVICES, LLC On the 24" day of October at 9:30 in the forenoon of that day, at the Supreme Court, Kings County, 360 Adams Street, Brooklyn, New York 11201, or as soon thereafter as counsel can be heard. An Order of the Court pursuant to CPLR §3042 and CPLR §3126, dismissing the plaintiff's Complaint; or, in the alternative, precluding plaintiff in offering any evidence at the time of trial relative to those items contained in the discovery demands to whichSUPPORTING PAPERS: ANSWERING PAPERS: Dated: Seaford, New York October 2, 2014 plaintiffs counsel has not yet provided responses; or, in the alternative, pursuant to CPLR Rule 3124, compelling plaintiff to provide all discovery responses by a date certain, with a conditional order of dismissal, along with such other and further relief as this Court deems just, proper and equitable. Affirmation of Timothy M. Shelley, Esq., and all other pleadings and proceedings heretofore had herein, and all exhibits annexed hereto and made a part hereof. Answering affirmation or affidavits, if any, must be served upon the undersigned attorneys at least seven (7) days prior to the return date of this motion pursuant to Rule 2214 of the CPLR. Yours, etc., KERLEY, WALSH, MATERA & CINQUEMAN|, P.C. By: TIMOTHY M.SHELDEY, ESQ. Attorneys for Defendant / RIVERDALE OSBORNE TOWERS HOUSING ASSOC. LLC and PROTO PROPERTY SERVICES, LLC 2174 Jackson Avenue Seaford, New York 11783 (516) 409-6200TO: MARC E. SEITELMAN LAW OFFICES, P.C. Attorney for Plaintiff 111 Broadway, 9" Floor New York, NY 10006 (212) 962-2626