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(FILED: KINGS COUNTY CLERK 0771572015 01:54 PM INDEX NO. 504489/2012
NYSCEF DOC. NO. 19 RECEIVED NYSCEF: 07/15/2015
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF KINGS
x
WILLIAM FLOYD ,
NOTICE OF MOTION
Plaintiff,
Index No.: 504489/2012
-against- IAS Part 7
NEW YORK CITY TRANSIT AUTHORITY,
METROPOLITAN TRANSPORTATION AUTHORITY
and "JANE DOE", SAID NAME BEING FICTICIOUS
AS TRUE NAME IS UNKNOWN,
Defendant(s).
PLEASE TAKE NOTICE, that upon the affirmation of TARA A. JOHNSON dated
July 13, 2015, and upon all the pleadings and proceedings heretofore had herein, the undersigned
will move this Court at an Individual Assignment Part 7 at the County of Kings Courthouse
located at 360 Adams St., Brooklyn, New York, 11201, on August 13, 2015 at 9:30 the forenoon
of that day, or as soon thereafter as counsel can be heard, for an order pursuant to CPLR § 3212
dismissing this matter in its entirety along with such other, further and different relief as to this
Court may seem just and proper. The above-entitled action is for bodily injury.
PLEASE TAKE FURTHER NOTICE, that pursuant to CPLR Section 2214 (b) you are
hereby required to serve all papers that will be used in opposition to this motion at least seven (7)
days prior to the return date of this motion.
Dated: New York, New York
July 13, 2015TO:
SAKKAS, CAHN & WEISS, LLP
Attorneys for Plaintiff WILLIAM FLOYD
150 Broadway, Suite 1307
New York, New York 10038
(212) 571-7171
Yours, etc.,
SHAFER GLAZER, LLP
ae RGR
Attorneys for Defendants
NEW YORK CITY TRANSIT AUTHORITY,
METROPOLITAN TRANSPORTATION
AUTHORITY AND "JANE DOE", SAID NAME
BEING FICTICIOUS AS TRUE NAME IS
UNKNOWN
125 Maiden Lane, 16" Floor
New York, New York 10038
(212) 267-0011
File No. MTA-00206INDEX NO.: 504489/2012
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF KINGS
WILLIAM FLOYD,
Plaintiff,
-against-
NEW YORK CITY TRANSIT AUTHORITY, METROPOLITAN
TRANSPORTATION AUTHORITY and "JANE DOE", SAID NAME BEING
FICTICIOUS AS TRUE NAME IS UNKNOWN,
Defendant
NOTICE OF MOTION
SHAFER GLAZER, LLP
Attorneys for Defendants
NEW YORK CITY TRANSIT AUTHORITY,
METROPOLITAN TRANSPORTATION AUTHORITY
AND "JANE DOE", SAID NAME BEING FICTICIOUS AS
TRUE NAME IS UNKNOWN,
90 John Street, Suite 701
New York, NY 10038-3202
(212) 267-0011
File No. MTA-00206
CERTIFICATION PURSUANT TO 22 N.Y.C.R.R. 1130-L1a
TARA A. JOHNSON hereby certifies that, pursuant to 22 N.Y.C.R.R. '130-1.1a, the foregoing Notice of Motion is
neither frivolous nor frivolously presented.
Dated: New York, New York
July 13, 2015
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(FILED: KINGS COUNTY CLERK 0771572015 01:54 PM INDEX NO. 504489/2012 NYSCEF DOC. NO. 19 RECEIVED NYSCEF: 07/15/2015 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF KINGS x WILLIAM FLOYD , NOTICE OF MOTION Plaintiff, Index No.: 504489/2012 -against- IAS Part 7 NEW YORK CITY TRANSIT AUTHORITY, METROPOLITAN TRANSPORTATION AUTHORITY and "JANE DOE", SAID NAME BEING FICTICIOUS AS TRUE NAME IS UNKNOWN, Defendant(s). PLEASE TAKE NOTICE, that upon the affirmation of TARA A. JOHNSON dated July 13, 2015, and upon all the pleadings and proceedings heretofore had herein, the undersigned will move this Court at an Individual Assignment Part 7 at the County of Kings Courthouse located at 360 Adams St., Brooklyn, New York, 11201, on August 13, 2015 at 9:30 the forenoon of that day, or as soon thereafter as counsel can be heard, for an order pursuant to CPLR § 3212 dismissing this matter in its entirety along with such other, further and different relief as to this Court may seem just and proper. The above-entitled action is for bodily injury. PLEASE TAKE FURTHER NOTICE, that pursuant to CPLR Section 2214 (b) you are hereby required to serve all papers that will be used in opposition to this motion at least seven (7) days prior to the return date of this motion. Dated: New York, New York July 13, 2015TO: SAKKAS, CAHN & WEISS, LLP Attorneys for Plaintiff WILLIAM FLOYD 150 Broadway, Suite 1307 New York, New York 10038 (212) 571-7171 Yours, etc., SHAFER GLAZER, LLP ae RGR Attorneys for Defendants NEW YORK CITY TRANSIT AUTHORITY, METROPOLITAN TRANSPORTATION AUTHORITY AND "JANE DOE", SAID NAME BEING FICTICIOUS AS TRUE NAME IS UNKNOWN 125 Maiden Lane, 16" Floor New York, New York 10038 (212) 267-0011 File No. MTA-00206INDEX NO.: 504489/2012 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF KINGS WILLIAM FLOYD, Plaintiff, -against- NEW YORK CITY TRANSIT AUTHORITY, METROPOLITAN TRANSPORTATION AUTHORITY and "JANE DOE", SAID NAME BEING FICTICIOUS AS TRUE NAME IS UNKNOWN, Defendant NOTICE OF MOTION SHAFER GLAZER, LLP Attorneys for Defendants NEW YORK CITY TRANSIT AUTHORITY, METROPOLITAN TRANSPORTATION AUTHORITY AND "JANE DOE", SAID NAME BEING FICTICIOUS AS TRUE NAME IS UNKNOWN, 90 John Street, Suite 701 New York, NY 10038-3202 (212) 267-0011 File No. MTA-00206 CERTIFICATION PURSUANT TO 22 N.Y.C.R.R. 1130-L1a TARA A. JOHNSON hereby certifies that, pursuant to 22 N.Y.C.R.R. '130-1.1a, the foregoing Notice of Motion is neither frivolous nor frivolously presented. Dated: New York, New York July 13, 2015