On December 20, 2019 a
Motion,Ex Parte
was filed
involving a dispute between
Veludi Capital Strategies,
and
Manuel Pereira,
for Commercial - Contract
in the District Court of Nassau County.
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FILED: NASSAU COUNTY CLERK 12/23/2019 02:33 PM INDEX NO. 617853/2019
NYSCEF DOC. NO. 7 RECEIVED NYSCEF: 12/24/2019
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF NASSAU
--------------------------------------------------------------------X Index No.
VELUDI CAPITAL STRATEGIES,
Plaintiff,
-against- NOTICE OF MOTION
FOR SUMMARY JUDGMENT
IN LIEU OF COMPLAINT
MANUEL PEREIRA,
Defendant,
..______ __ __.-
---------X
PLEASE TAKE NOTICE, that upon the Summons dated December 20, 2019, the
Affirmation of Craig Riha, affirmed on December 20, 2019 and the Affidavit of Chander Goel,
with exhibits, sworn to on December 18, 2019 the undersigned will move this Court at an IAS
Part to be assigned to the Nassau County Supreme Court Courthouse, located at 100 Supreme
31S
Court Drive Mineola, New York, 11501, County of Nassau, on the day of January, 2020 at
9:30 a.m., or as soon thereafter as counsel may be heard, for an order pursuant to CPLR 3213
granting Plaintiff Summary Judgment in lieu of Complaint against Defendant, in the principal
sum of Seven Hundred Thousand Dollars ($700,000.00), together with accrued and unpaid
interest thereon, default interest thereafter, all calculated in accordance with the related
attorneys'
Promissory Note, through the date of payment in full, and for Plaintiffs fees and
expenses as provided in the Promissory Note, upon the ground that this action is based upon an
instrument for the payment of money only, and there is no defense thereto, and for such other
and further relief as to this Court may seem just and proper, together with the costs and
disbursements of this action.
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FILED: NASSAU COUNTY CLERK 12/23/2019 02:33 PM INDEX NO. 617853/2019
NYSCEF DOC. NO. 7 RECEIVED NYSCEF: 12/24/2019
PLEASE TAKE FURTHER NOTICE, that pursuant to CPLR 3213, answering affidavits,
if any, are required to be served upon the undersigned at least seven (7) days before the return date
of this motion.
Dated: Bohemia, New York
December 20, 2019
Craig A. iha
CARMEL, MILAZZO, AND DICHIARA, LLP
Attorneys for Plaintiff
3920 Veterans Memorial Highway, Suite 8
Bohemia, NY 11716
(212) 658-0458
TO: Manuel Pereira
609 Edgewood Drive
Westbury, New York 11590
2 of 2
Document Filed Date
December 23, 2019
Case Filing Date
December 20, 2019
Category
Commercial - Contract
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FILED: NASSAU COUNTY CLERK 12/23/2019 02:33 PM INDEX NO. 617853/2019 NYSCEF DOC. NO. 7 RECEIVED NYSCEF: 12/24/2019 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF NASSAU --------------------------------------------------------------------X Index No. VELUDI CAPITAL STRATEGIES, Plaintiff, -against- NOTICE OF MOTION FOR SUMMARY JUDGMENT IN LIEU OF COMPLAINT MANUEL PEREIRA, Defendant, ..______ __ __.- ---------X PLEASE TAKE NOTICE, that upon the Summons dated December 20, 2019, the Affirmation of Craig Riha, affirmed on December 20, 2019 and the Affidavit of Chander Goel, with exhibits, sworn to on December 18, 2019 the undersigned will move this Court at an IAS Part to be assigned to the Nassau County Supreme Court Courthouse, located at 100 Supreme 31S Court Drive Mineola, New York, 11501, County of Nassau, on the day of January, 2020 at 9:30 a.m., or as soon thereafter as counsel may be heard, for an order pursuant to CPLR 3213 granting Plaintiff Summary Judgment in lieu of Complaint against Defendant, in the principal sum of Seven Hundred Thousand Dollars ($700,000.00), together with accrued and unpaid interest thereon, default interest thereafter, all calculated in accordance with the related attorneys' Promissory Note, through the date of payment in full, and for Plaintiffs fees and expenses as provided in the Promissory Note, upon the ground that this action is based upon an instrument for the payment of money only, and there is no defense thereto, and for such other and further relief as to this Court may seem just and proper, together with the costs and disbursements of this action. 1 of 2 FILED: NASSAU COUNTY CLERK 12/23/2019 02:33 PM INDEX NO. 617853/2019 NYSCEF DOC. NO. 7 RECEIVED NYSCEF: 12/24/2019 PLEASE TAKE FURTHER NOTICE, that pursuant to CPLR 3213, answering affidavits, if any, are required to be served upon the undersigned at least seven (7) days before the return date of this motion. Dated: Bohemia, New York December 20, 2019 Craig A. iha CARMEL, MILAZZO, AND DICHIARA, LLP Attorneys for Plaintiff 3920 Veterans Memorial Highway, Suite 8 Bohemia, NY 11716 (212) 658-0458 TO: Manuel Pereira 609 Edgewood Drive Westbury, New York 11590 2 of 2