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INDEX NO. 651458/2012
NYSCEF DOC. NO. 9 RECEIVED NYSCEF: 08/22/2012
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF NEW YORK
--------------------------------------
RAYMOND SANCHEZ, GUILLERMO SECO
and GRAMERCY PARK MEDICAL GROUP, Index No: 651458/2012
P.C.,
Plaintiffs, NOTICE OF MOTION
TO DISMISS
-against-
LARRY KROLL, GRAMERCY PARK
SERVCES, LLC, and COMPREHENSIVE
CONSULTING, INC.
Defendants.
--------------------------------------
PLEASE TAKE NOTICE, that upon the Affirmation of Bradley S. Gross, Esq., dated
August 22, 2012, the Exhibit annexed thereto, the Memorandum of Law in Support of the
Defendants’ Motion to Dismiss, and upon all of the papers and proceedings heretofore had
herein, the undersigned, attorney for Defendants, will move this Honorable Court by way of
Motion, at the Courthouse located at 60 Centre Street, New York, New York, in room 130
thereof, on the 5th Day of October, 2012, at 9:30 in the forenoon of that day, or as soon thereafter
as counsel can be heard, for the issuance of an Order herein, granting dismissal of the within
Amended Verified Complaint, dated July 9, 2012, and each of the claims therein interposed,
pursuant to CPLR 3211(a)(1), (3), (5) and (7), and in further support of their prayer for dismissal
of the First Cause of Action, pursuant to CPLR 3016 (b), and granting plaintiff such other further
and different relief as this Court shall deem to be just, fit and proper, in these premises.
PLEASE TAKE FURTHER NOTICE, answering papers, if any, are to be served no later
than seven days prior to the return date of this motion.
Dated: New York, New York
August 22, 2012
BRADLEY S. GROSS, ESQ.
Attorney for Defendants
45 Rockefeller Plaza - Suite 2000
New York, NY 10111
(212) 732-7412
TO: R. David Marquez, PC
Attorney for the Plaintiffs
50 Clinton Street, Ste 214
Hempstead, New York 11550
516-478-9302
SUPREME COURT OF THE STATE OF NEW YORK INDEX NO: 651458/2012
COUNTY OF NEW YORK
RAYMOND SANCHEZ, GUILLERMO SECO and
GRAMERCY PARK MEDICAL GROUP, P.C.,
Plaintiffs,
-against-
LARRY KROLL, GRAMERCY PARK SERVCES, LLC,
and COMPREHENSIVE CONSULTING, INC.
Defendants.
NOTICE OF MOTION TO DISMISS
BRADLEY S. GROSS, ESQ.
ATTORNEY FOR DEFENDANTS
45 ROCKEFELLER PLAZA – SUITE 2000
NEW YORK, NEW YORK 10111
(212) 732-7412
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INDEX NO. 651458/2012 NYSCEF DOC. NO. 9 RECEIVED NYSCEF: 08/22/2012 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF NEW YORK -------------------------------------- RAYMOND SANCHEZ, GUILLERMO SECO and GRAMERCY PARK MEDICAL GROUP, Index No: 651458/2012 P.C., Plaintiffs, NOTICE OF MOTION TO DISMISS -against- LARRY KROLL, GRAMERCY PARK SERVCES, LLC, and COMPREHENSIVE CONSULTING, INC. Defendants. -------------------------------------- PLEASE TAKE NOTICE, that upon the Affirmation of Bradley S. Gross, Esq., dated August 22, 2012, the Exhibit annexed thereto, the Memorandum of Law in Support of the Defendants’ Motion to Dismiss, and upon all of the papers and proceedings heretofore had herein, the undersigned, attorney for Defendants, will move this Honorable Court by way of Motion, at the Courthouse located at 60 Centre Street, New York, New York, in room 130 thereof, on the 5th Day of October, 2012, at 9:30 in the forenoon of that day, or as soon thereafter as counsel can be heard, for the issuance of an Order herein, granting dismissal of the within Amended Verified Complaint, dated July 9, 2012, and each of the claims therein interposed, pursuant to CPLR 3211(a)(1), (3), (5) and (7), and in further support of their prayer for dismissal of the First Cause of Action, pursuant to CPLR 3016 (b), and granting plaintiff such other further and different relief as this Court shall deem to be just, fit and proper, in these premises. PLEASE TAKE FURTHER NOTICE, answering papers, if any, are to be served no later than seven days prior to the return date of this motion. Dated: New York, New York August 22, 2012 BRADLEY S. GROSS, ESQ. Attorney for Defendants 45 Rockefeller Plaza - Suite 2000 New York, NY 10111 (212) 732-7412 TO: R. David Marquez, PC Attorney for the Plaintiffs 50 Clinton Street, Ste 214 Hempstead, New York 11550 516-478-9302 SUPREME COURT OF THE STATE OF NEW YORK INDEX NO: 651458/2012 COUNTY OF NEW YORK RAYMOND SANCHEZ, GUILLERMO SECO and GRAMERCY PARK MEDICAL GROUP, P.C., Plaintiffs, -against- LARRY KROLL, GRAMERCY PARK SERVCES, LLC, and COMPREHENSIVE CONSULTING, INC. Defendants. NOTICE OF MOTION TO DISMISS BRADLEY S. GROSS, ESQ. ATTORNEY FOR DEFENDANTS 45 ROCKEFELLER PLAZA – SUITE 2000 NEW YORK, NEW YORK 10111 (212) 732-7412