On August 07, 2012 a
Motion,Ex Parte
was filed
involving a dispute between
Jason Graham,
and
Elias Properties Flatbush,Llc,,
Tmobile Usa, Inc.,,
for Tort
in the District Court of Nassau County.
Preview
(FILED: NASSAU COUNTY CLERK 12705/2014 12:28 PM INDEX NO. 600285/2013
NYSCEF DOC. NO. 51 RECEIVED NYSCEF: 12/05/2014
E-FILE
12-4752
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF NASSAU
Potente reat ote z
JASON GRAHAM, : Index No.: 600285/2013
Plaintiff(s), :
-against- : NOTICE OF MOTION
T-MOBILE USA, INC. and ELIAS : HON. JOHN GALASSO
PROPERTIES FLATBUSH, LLC,
Defendant(s).
PLEASE TAKE NOTICE that upon the affirmation of James V. Sawicki, dated
December 5, 2014, the exhibits attached thereto and upon all prior papers and
proceedings had herein, defendant ELIAS PROPERTIES FLATBUSH, LLC, will move
this Court in the Centralized Motions Part, Room 152 at the Courthouse located at the
Supreme Court, Nassau County, 100 Supreme Court Drive, Mineola, New York 11501
on January 7", 2015, at 9:30 a.m., or as soon thereafter as counsel may be heard, for
an Order pursuant to 22 N.Y.C.R.R. §202.21(e) vacating plaintiffs Note of Issue and
Certificate of Readiness; compelling plaintiff provide all outstanding discovery, appear
for deposition; and extend defendant's time to move for summary judgment to 120 days
after the completion of all discovery in this matter, together with such other and further
relief as the Court deems just and proper.
Plaintiff seeks damages for injuries allegedly sustained due to defendant's
negligence.Pursuant to CPLR 2214(b) answering affidavits, if any, must be served upon the
undersigned at least seven days before the return date of the motion.
Dated:New York, New York
December 5, 2014
Gannon, Rosenfi ssman
By: ¢
Attorneys for Defendant
ELIAS PROPERTIES FLATBUSH, LLC
100 William Street, 7th Floor
New York, New York 10038
(212) 655-5000
TO:
GEORGE T. PETERS
Attorney for Plaintiff
402 West 145th Street, 2nd FI.
New York, New York 10031
(347) 751-0157
SMITH MAZURE DIRECTOR
WILKINS YOUNG & YAGERMAN, P.C.
Attorneys for Defendant
T-Mobile USA, Inc.
111 John Street — 20" FI
New York, New York 20038
(212) 964-7400
Document Filed Date
December 05, 2014
Case Filing Date
August 07, 2012
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(FILED: NASSAU COUNTY CLERK 12705/2014 12:28 PM INDEX NO. 600285/2013 NYSCEF DOC. NO. 51 RECEIVED NYSCEF: 12/05/2014 E-FILE 12-4752 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF NASSAU Potente reat ote z JASON GRAHAM, : Index No.: 600285/2013 Plaintiff(s), : -against- : NOTICE OF MOTION T-MOBILE USA, INC. and ELIAS : HON. JOHN GALASSO PROPERTIES FLATBUSH, LLC, Defendant(s). PLEASE TAKE NOTICE that upon the affirmation of James V. Sawicki, dated December 5, 2014, the exhibits attached thereto and upon all prior papers and proceedings had herein, defendant ELIAS PROPERTIES FLATBUSH, LLC, will move this Court in the Centralized Motions Part, Room 152 at the Courthouse located at the Supreme Court, Nassau County, 100 Supreme Court Drive, Mineola, New York 11501 on January 7", 2015, at 9:30 a.m., or as soon thereafter as counsel may be heard, for an Order pursuant to 22 N.Y.C.R.R. §202.21(e) vacating plaintiffs Note of Issue and Certificate of Readiness; compelling plaintiff provide all outstanding discovery, appear for deposition; and extend defendant's time to move for summary judgment to 120 days after the completion of all discovery in this matter, together with such other and further relief as the Court deems just and proper. Plaintiff seeks damages for injuries allegedly sustained due to defendant's negligence.Pursuant to CPLR 2214(b) answering affidavits, if any, must be served upon the undersigned at least seven days before the return date of the motion. Dated:New York, New York December 5, 2014 Gannon, Rosenfi ssman By: ¢ Attorneys for Defendant ELIAS PROPERTIES FLATBUSH, LLC 100 William Street, 7th Floor New York, New York 10038 (212) 655-5000 TO: GEORGE T. PETERS Attorney for Plaintiff 402 West 145th Street, 2nd FI. New York, New York 10031 (347) 751-0157 SMITH MAZURE DIRECTOR WILKINS YOUNG & YAGERMAN, P.C. Attorneys for Defendant T-Mobile USA, Inc. 111 John Street — 20" FI New York, New York 20038 (212) 964-7400