Preview
FILED: KINGS COUNTY CLERK 06/24/2020 11:32 AM INDEX NO. 526735/2019
NYSCEF DOC. NO. 17 RECEIVED NYSCEF: 06/24/2020
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF KINGS
------ -------------------- X Index No. 526735/19
ANDREY PIKALOV,
Plaintiff, NOTICE OF MOTION
-against-
Assigned to:
Hon. Pamela L Rsher
LAM CHI CHI, PAUL SCOTT SCHAEDTLER,
and YOEL HENRIQUEZ, Return Date: 07/29/20
Defendants.
---------X
MOVING PARTY: SCAHILL LAW GROUP P.C.
Attorneys for the Defendant
CHI LAM CHI s/h/a LAM CHI CHI
RETURN DATE , TIME & PLACE: July 29, 2020, at an IAS Part of the
Courthouse, located at 360 Adams Street,
Brooklyn, New York 11201, at 10:00 a.m.
SUPPORTING PAPERS: Affirmation of CHRISTOPHER J. McCUNE
and Annexed Exhibits.
RELIEF REQUESTED: An Order, pursuant to CPLR §
3212, for Summary Judgment due to
the plaintifFs failure to prove a prima
facie case of liability against the
defendant, CHI LAM CHI, and dismissing
any and all crossclaims or counterclaims
against him.
ANSWERING AFFIDAVITS: Must be served at least 7 days prior to
the return date of this Motion, pursuant
to CPLR § 2214(b).
CERTIFICATION: Pursuant to 22 NYCRR § 130-1.1, it is
hereby certified that to the best of the
undersigned's knowledge, information,
and belief, formed after an inquiry
reasonable under the circumstances, the
presentation and contentions therein of
the annexed papers are not frivolous as
1
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FILED: KINGS COUNTY CLERK 06/24/2020 11:32 AM INDEX NO. 526735/2019
NYSCEF DOC. NO. 17 RECEIVED NYSCEF: 06/24/2020
defined by 22 NYCRR § 1.1(c).
Dated: Bethpage, New York
June 23, 2020
Yours, etc.,
ChrDJor>her McCtmo
CHRISTOPHER J. McCUNE
SCAHILL LAW GROUP P.C.
Attorneys for the Defendant
CHI LAM CHI s/h/a LAM CHI CHI
1065 Stewart Avenue, Suite 210
Bethpage, New York 11714
(516) 294-5200
Our File No.: 0428328960101030
TO: LEVITSKY LAW FIRM
Attorneys for Plaintiff
ANDREY PIKALOV
2nd
3163 Coney Island Avenue, FlOOr
Brooklyn, NY 11235
(347) 462-1660
JAMES G. BILELLO & ASSOCIATES
Attorneys for Co-Defendant
YOEL HENRIQUEZ
100 Duffy Avenue, Suite 500
Hicksville, NY 11801
(516) 861-1840
O'CONNOR, MCGUINNESS, CONTE, DOYLE,
OLESON, WATSON & LOFTUS, LLP
Attorneys for Co-Defendant
PAUL SCOTT SCHAEDTLER
One Barker Avenue, Suite 675
White Plains, NY 10601
(914) 948-4500
2
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FILED: KINGS COUNTY CLERK 06/24/2020 11:32 AM INDEX NO. 526735/2019
NYSCEF DOC. NO. 17 RECEIVED NYSCEF: 06/24/2020
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF KINGS
Index No. 526735/19
ANDREY PIKALOV,
Plaintiff,
-against-
LAM CHI CHI, PAUL SCOTT SCHAEDTLER,
and YOEL HENRIQUEZ,
Defendants.
NOTICE OF MOTION AND AFFIRMATION
SCAHILL LAW GROUP P.C.
Attorneys for the Defendant
CHI LAM CHI s/h/a LAM CHI CHI
1065 Stewart Avenue, Suite 210
Bethpage, New York 11714
(516) 294-5200
ATTORNEY CERTIFICATION
Pursuant to 22 NYCRR § 130-1.1, the undersigned, an attoliiey admitted to practice in the courts of New
York State, certifies that upon infoniiciüun and belief and responsible inquiry, the contentions contained
in the annexed documents are not frivolous.
Dated: June 23, 2020
Ch-r is4or>¾er N\cotMe
CHRISTOPHER J. McCUNE, E SQ.
Please take notice
O Notice of entry
that the within is a (certified) true copy of a duly entered in the office of the clerk of the within
namedcoudon .
ONotice of Settlement
^ of which
that an order the within is a true copy will be presented for settlement to the HON.
one of the judges of the within named court, at ___ ___ on .
Dated: Bethpage, New York
Yours, etc.
SCAHILL LAW GROUP P.C.
Attorneys for the Defendant
CHI LAM CHI s/h/a LAM CHI CHI
To: All Parties 1065 Stewart Avenue, Suite 210
Bethpage, New York 11714
(516) 294-5200
12
3 of 3
Preview
FILED: KINGS COUNTY CLERK 06/24/2020 11:32 AM INDEX NO. 526735/2019 NYSCEF DOC. NO. 17 RECEIVED NYSCEF: 06/24/2020 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF KINGS ------ -------------------- X Index No. 526735/19 ANDREY PIKALOV, Plaintiff, NOTICE OF MOTION -against- Assigned to: Hon. Pamela L Rsher LAM CHI CHI, PAUL SCOTT SCHAEDTLER, and YOEL HENRIQUEZ, Return Date: 07/29/20 Defendants. ---------X MOVING PARTY: SCAHILL LAW GROUP P.C. Attorneys for the Defendant CHI LAM CHI s/h/a LAM CHI CHI RETURN DATE , TIME & PLACE: July 29, 2020, at an IAS Part of the Courthouse, located at 360 Adams Street, Brooklyn, New York 11201, at 10:00 a.m. SUPPORTING PAPERS: Affirmation of CHRISTOPHER J. McCUNE and Annexed Exhibits. RELIEF REQUESTED: An Order, pursuant to CPLR § 3212, for Summary Judgment due to the plaintifFs failure to prove a prima facie case of liability against the defendant, CHI LAM CHI, and dismissing any and all crossclaims or counterclaims against him. ANSWERING AFFIDAVITS: Must be served at least 7 days prior to the return date of this Motion, pursuant to CPLR § 2214(b). CERTIFICATION: Pursuant to 22 NYCRR § 130-1.1, it is hereby certified that to the best of the undersigned's knowledge, information, and belief, formed after an inquiry reasonable under the circumstances, the presentation and contentions therein of the annexed papers are not frivolous as 1 1 of 3 FILED: KINGS COUNTY CLERK 06/24/2020 11:32 AM INDEX NO. 526735/2019 NYSCEF DOC. NO. 17 RECEIVED NYSCEF: 06/24/2020 defined by 22 NYCRR § 1.1(c). Dated: Bethpage, New York June 23, 2020 Yours, etc., ChrDJor>her McCtmo CHRISTOPHER J. McCUNE SCAHILL LAW GROUP P.C. Attorneys for the Defendant CHI LAM CHI s/h/a LAM CHI CHI 1065 Stewart Avenue, Suite 210 Bethpage, New York 11714 (516) 294-5200 Our File No.: 0428328960101030 TO: LEVITSKY LAW FIRM Attorneys for Plaintiff ANDREY PIKALOV 2nd 3163 Coney Island Avenue, FlOOr Brooklyn, NY 11235 (347) 462-1660 JAMES G. BILELLO & ASSOCIATES Attorneys for Co-Defendant YOEL HENRIQUEZ 100 Duffy Avenue, Suite 500 Hicksville, NY 11801 (516) 861-1840 O'CONNOR, MCGUINNESS, CONTE, DOYLE, OLESON, WATSON & LOFTUS, LLP Attorneys for Co-Defendant PAUL SCOTT SCHAEDTLER One Barker Avenue, Suite 675 White Plains, NY 10601 (914) 948-4500 2 2 of 3 FILED: KINGS COUNTY CLERK 06/24/2020 11:32 AM INDEX NO. 526735/2019 NYSCEF DOC. NO. 17 RECEIVED NYSCEF: 06/24/2020 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF KINGS Index No. 526735/19 ANDREY PIKALOV, Plaintiff, -against- LAM CHI CHI, PAUL SCOTT SCHAEDTLER, and YOEL HENRIQUEZ, Defendants. NOTICE OF MOTION AND AFFIRMATION SCAHILL LAW GROUP P.C. Attorneys for the Defendant CHI LAM CHI s/h/a LAM CHI CHI 1065 Stewart Avenue, Suite 210 Bethpage, New York 11714 (516) 294-5200 ATTORNEY CERTIFICATION Pursuant to 22 NYCRR § 130-1.1, the undersigned, an attoliiey admitted to practice in the courts of New York State, certifies that upon infoniiciüun and belief and responsible inquiry, the contentions contained in the annexed documents are not frivolous. Dated: June 23, 2020 Ch-r is4or>¾er N\cotMe CHRISTOPHER J. McCUNE, E SQ. Please take notice O Notice of entry that the within is a (certified) true copy of a duly entered in the office of the clerk of the within namedcoudon . ONotice of Settlement ^ of which that an order the within is a true copy will be presented for settlement to the HON. one of the judges of the within named court, at ___ ___ on . Dated: Bethpage, New York Yours, etc. SCAHILL LAW GROUP P.C. Attorneys for the Defendant CHI LAM CHI s/h/a LAM CHI CHI To: All Parties 1065 Stewart Avenue, Suite 210 Bethpage, New York 11714 (516) 294-5200 12 3 of 3