On December 03, 2012 a
Motion,Ex Parte
was filed
involving a dispute between
Nidal Abou Trabah,
and
Shemsan Grocery A K A Deli & Grill,
Zane Munassa,
Z&N Hillside Sutphin Llc,
for Tort
in the District Court of Kings County.
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INDEX NO. 504087/2012
NYSCEF DOC. NO. 102 RECEIVED NYSCEF: 09/07/2016
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF KINGS
nescence cnet a nnn enn n nena nnnnnnnnnnnnnnnnnnnn nnn x Index No.
NIDAL ABOU TRABAH, 504087/12
Plaintiff,
-against- NOTICE OF
Z & N HILLSIDE/SUTPHIN LLC, ZANE MUNASSA, MOTION
and SHEMSAN GROCERY a/k/a DELI & GRILL,
Defendants.
sseeoneseenrrresemmemnennng=nenanannnnenneasoao-asecusssseseannnmansna==taan ty
PLEASE TAKE NOTICE that, upon the annexed Affirmation of Good Faith, dated
September 7, 2016, of Edward C. Lehman, upon the annexed Affirmation in Support of Edward
C. Lehman, dated September 7, 2016, and upon all the pleadings and proceedings heretofore had
herein, the undersigned will move this Court before the Honorable Carolyn E. Wade at Part 84,
Room 423, of the Kings County Courthouse located at 360 Adams Street, Brooklyn, New York,
on the 30" day of September, 2016 at 9:30 in the forenoon, or as soon thereafier as counsel can
be heard, for an order:
(a) Pursuant to CPLR 3124 and CPLR 3126, striking the Answers of defendants for
failure to appear for court-ordered Examinations Before Trial;
(b) Extending plaintiff's time to file note of issue; and
(b) Granting such other, further and different relief as this Court deems just and proper.
PLEASE TAKE FURTHER NOTICE that, pursuant to CPLR 2214(b), answering
affidavits, if any, shall be served upon the undersigned no later than seven (7) days before the
return date hereof.
1 of 2Dated: Jackson Heights, New York
To:
September 7, 2016
Morrison Mahoney LLP
120 Broadway, Suite 1010
New York, New York 10271
212-825-1212
2 of 2
Yours, etc.,
Chad l, Lehn
Edward C, Lehman
Bhurtel Law Firm PIC
37-49 75" Street, 2! Floor
Jackson Heights, New York
718-509-6181
Preview
INDEX NO. 504087/2012 NYSCEF DOC. NO. 102 RECEIVED NYSCEF: 09/07/2016 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF KINGS nescence cnet a nnn enn n nena nnnnnnnnnnnnnnnnnnnn nnn x Index No. NIDAL ABOU TRABAH, 504087/12 Plaintiff, -against- NOTICE OF Z & N HILLSIDE/SUTPHIN LLC, ZANE MUNASSA, MOTION and SHEMSAN GROCERY a/k/a DELI & GRILL, Defendants. sseeoneseenrrresemmemnennng=nenanannnnenneasoao-asecusssseseannnmansna==taan ty PLEASE TAKE NOTICE that, upon the annexed Affirmation of Good Faith, dated September 7, 2016, of Edward C. Lehman, upon the annexed Affirmation in Support of Edward C. Lehman, dated September 7, 2016, and upon all the pleadings and proceedings heretofore had herein, the undersigned will move this Court before the Honorable Carolyn E. Wade at Part 84, Room 423, of the Kings County Courthouse located at 360 Adams Street, Brooklyn, New York, on the 30" day of September, 2016 at 9:30 in the forenoon, or as soon thereafier as counsel can be heard, for an order: (a) Pursuant to CPLR 3124 and CPLR 3126, striking the Answers of defendants for failure to appear for court-ordered Examinations Before Trial; (b) Extending plaintiff's time to file note of issue; and (b) Granting such other, further and different relief as this Court deems just and proper. PLEASE TAKE FURTHER NOTICE that, pursuant to CPLR 2214(b), answering affidavits, if any, shall be served upon the undersigned no later than seven (7) days before the return date hereof. 1 of 2Dated: Jackson Heights, New York To: September 7, 2016 Morrison Mahoney LLP 120 Broadway, Suite 1010 New York, New York 10271 212-825-1212 2 of 2 Yours, etc., Chad l, Lehn Edward C, Lehman Bhurtel Law Firm PIC 37-49 75" Street, 2! Floor Jackson Heights, New York 718-509-6181