On June 19, 2012 a
Motion,Ex Parte
was filed
involving a dispute between
Patrick Keen,
and
Challenger Properties, Llc,
Majestic Realty Associates Llc,
New York Smsa Limited Partnership D B A Verizon Wireless,
for Tort
in the District Court of New York County.
Preview
INDEX NO. 153809/2012
FILED: NEW YORK COUNTY CLERK 04/25/2013
NYSCEF DOC. NO. 47 RECEIVED NYSCEF: 04/25/2013
(
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF NEW YORK
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PATRICK KEEN,
Index No. 153809/12
Plaintiff,
NOTICE OF
~ against - MOTION
MAJESTIC REALTY ASSOCIATES LLC,
CHALLENGER PROPERTIES, LLC and
NEW YORK SMSA LIMITED PARTNERSHIP
d/b/a VERIZON WIRELESS,
Defendants.
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MAJESTIC REALTY ASSOCIATES LLC AND
CHALLENGER PROPERTIES, LLC
Third-Party Plaintiffs, Index No. 590222/13
-against-
NEW YORK SMSA LIMITED PARTNERSHIP
d/b/a VERIZON WIRELESS,
Third-Party Defendant
= nonX
SIRS:
PLEASE TAKE NOTICE, that upon the annexed affirmation of Deborah Bass,
dated the 23% day of April, 2013, and the exhibits annexed thereto, -and upon all the
pleadings and proceedings heretofore had herein, and the annexed memorandum of
law, the undersigned will move this court, at an IAS Motion Courtroom 130, to be held
at the courthouse located at 60 Centre Street, New York, York, New York, on the 24"
day of May, 2013, at 9:30 o’clock in the forenoon of that day, or as soon thereafter as
counsel may be heard, for an order, pursuant to CPLR 3212, granting summary
judgment in favor of defendant/third-party-defendant New York SMSA Limited
Partnership d/b/a Verizon Wireless dismissing plaintiff's amended complaint on the
ground that plaintiff's claims are barred by the statute of limitations, and for such other +
further, and different relief as to this court may seem just and proper.
PLEASE TAKE FURTHER NOTICE, that answering affidavits, if any, must be
served at least seven (7) days prior to the return date of the within motion.
Dated: New York, New York
April 23, 2013
00 Ge
Deborah Bass
Ledy-Gurren, Bass & Siff, LLP
Attorneys for Defendant/Third-Party Defendant
New York SMSA Limited Partnership
d/b/a Verizon Wireless
475 Park Avenue South
New York, New York 10016
(212) 447-1111
To: The Stein Law Group, PLLC
Attorneys for Plaintiff
Patrick Keen
350 Fifth Avenue, Suite 7210
New York, New York 10118
(212) 465-1110
Kaufman Borgeest & Ryan LLP
Attorneys for Defendants/Third-Party Plaintiffs
Majestic Realty Associates LLC and
Challenger Properties, LLC
120 Broadway-14th Floor
New York, New York 10271
(212) 980-9600
File No. 163.027
Document Filed Date
April 25, 2013
Case Filing Date
June 19, 2012
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