On November 01, 2013 a
Motion,Ex Parte
was filed
involving a dispute between
Lazaro Sanchez,
and
Chan Ying,
Chi Hung,
Extra Space Storage Inc.,
Gabriel Castano,
Jerilynn Horton,
for Tort
in the District Court of Bronx County.
Preview
INDEX NO. 24105/2013E
NYSCEF DOC. NO. 93 RECEIVED NYSCEF 11/08/2016
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF BRONX
LAZARO SANCHEZ, Index No.: 24105/2013e
Plaintiff,
-against- NOTICE OF MOTION
EXTRA SPACE STORAGE, INC., GABRIEL
CASTANO, JERILYNN HORTON, CHI HUNG AND :
5
CHAN YING
Defendants.
eniennen aera Ee nRnn Renn R RSET R GSS
EXTRA SPACE MANAGEMENT, INC.,
Third Party Index No.: 24105/2013e
Third Party
Plaintiff,
-against-
JR BUILDING SERVICE, INC.
Third Party Defendant.
2 ies sine tte ate ee en en eR NIE
PLEASE TAKE NOTICE, that upon the annexed affirmation of Scott H. Goldstein,
affirmed on November 7, 2016, together with the exhibits annexed thereto, and upon all the
pleadings and proceedings heretofore had herein, the undersigned will move this Court at the IAS
Motion part at the Bronx County Supreme Court of New York, located at 851 Grand Concourse,
Bronx, NY 10451 on November 29, 2016 at 9:30 A.M. for an Order pursuant to CPLR §3215,
Defendant/Third Party Plaintiff EXTRA SPACE MANAGEMENT, INC.’s Third Party Complaint
seeking default against Third party Defendant JR BUILDING SERVICE, INC. for failure to Answer
1 of 2
to Defendant/Third Party Plaintiff EXTRA SPACE MANAGEMENT, INC.’S Third Party
Complaint; and for such other and further relief as to this Court deems just and proper.
PLEASE TAKE FURTHER NOTICE, that answering Affidavits, if any, are to be served
upon the undersigned within seven (7) days of the return date hereof pursuant to CPLR §2214(b).
DATED: New York, New York
November 7, 2016
By:
Scott H. Goldstein, Esq.
BONNER KIERNAN TREBACH
& CROCIATA, LLP
Attorneys for Defendant/Third Party Plaintiff
EXTRA SPACE MANAGEMENT, INC.
New York, New York 10118
(212) 268-7535
TO:
JR Building Service, Inc.
c/o Ramiro Juarez
571 Halleck Street
Bronx, NY 10474
Ronemus & Velensky
Attorney for Plaintiff
112 Madison Avenue, 2"¢ Floor
New York, NY 10016
Penino & Moyniham, LLP.
Attorneys for Defendants Chi Hung and Chan Ying
1025 Westchester Avenue, Suite 403
White Plains, NY 10604
Richard T. Lau & Associates
Attorneys for Defendant Gabriel Castano
P.O. Box 9040
Jericho, NY 11753
2 of 2
Document Filed Date
November 08, 2016
Case Filing Date
November 01, 2013
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INDEX NO. 24105/2013E NYSCEF DOC. NO. 93 RECEIVED NYSCEF 11/08/2016 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF BRONX LAZARO SANCHEZ, Index No.: 24105/2013e Plaintiff, -against- NOTICE OF MOTION EXTRA SPACE STORAGE, INC., GABRIEL CASTANO, JERILYNN HORTON, CHI HUNG AND : 5 CHAN YING Defendants. eniennen aera Ee nRnn Renn R RSET R GSS EXTRA SPACE MANAGEMENT, INC., Third Party Index No.: 24105/2013e Third Party Plaintiff, -against- JR BUILDING SERVICE, INC. Third Party Defendant. 2 ies sine tte ate ee en en eR NIE PLEASE TAKE NOTICE, that upon the annexed affirmation of Scott H. Goldstein, affirmed on November 7, 2016, together with the exhibits annexed thereto, and upon all the pleadings and proceedings heretofore had herein, the undersigned will move this Court at the IAS Motion part at the Bronx County Supreme Court of New York, located at 851 Grand Concourse, Bronx, NY 10451 on November 29, 2016 at 9:30 A.M. for an Order pursuant to CPLR §3215, Defendant/Third Party Plaintiff EXTRA SPACE MANAGEMENT, INC.’s Third Party Complaint seeking default against Third party Defendant JR BUILDING SERVICE, INC. for failure to Answer 1 of 2 to Defendant/Third Party Plaintiff EXTRA SPACE MANAGEMENT, INC.’S Third Party Complaint; and for such other and further relief as to this Court deems just and proper. PLEASE TAKE FURTHER NOTICE, that answering Affidavits, if any, are to be served upon the undersigned within seven (7) days of the return date hereof pursuant to CPLR §2214(b). DATED: New York, New York November 7, 2016 By: Scott H. Goldstein, Esq. BONNER KIERNAN TREBACH & CROCIATA, LLP Attorneys for Defendant/Third Party Plaintiff EXTRA SPACE MANAGEMENT, INC. New York, New York 10118 (212) 268-7535 TO: JR Building Service, Inc. c/o Ramiro Juarez 571 Halleck Street Bronx, NY 10474 Ronemus & Velensky Attorney for Plaintiff 112 Madison Avenue, 2"¢ Floor New York, NY 10016 Penino & Moyniham, LLP. Attorneys for Defendants Chi Hung and Chan Ying 1025 Westchester Avenue, Suite 403 White Plains, NY 10604 Richard T. Lau & Associates Attorneys for Defendant Gabriel Castano P.O. Box 9040 Jericho, NY 11753 2 of 2