On November 21, 2019 a
Motion,Ex Parte
was filed
involving a dispute between
Robert C Beardsley,
Robyn Beardsley,
and
Evans Land Corp,
Frederick M Manguso,
for Commercial - Contract
in the District Court of Cattaraugus County.
Preview
FILED: CATTARAUGUS COUNTY CLERK 11/27/2019 12:22 PM INDEX NO. 86157
NYSCEF DOC. NO. 3 (" RECEIVED NYSCEF: 11/27/2019
STATE OF NEW YORK
SUPREME COURT: COUNTY OF CATTARGUS
ROBERT C. BEARDSLEY and
ROBYN BEARDSLEY,
Plaintiffs,
Index No. 86157
v. -Index-Nu:-87-1-8'7-
Hon. Jeremiah J. Moriarty III
EVANS LAND CORPORATION and
FREDERICK M. MANGUSO,
Defendants ..
NOTICE OF MOTION
Nature of Action: Derivative suit.
Moving Party: Plaintiffs.
Directed To: Defendants.
Date, Time and Place: December 5, 2019 at 9:30 a.m. before the
Hon. Jeremiah J. Moriarty III, J~S.C.,
. 303 Court Street, 2nd Floor,
Little Valley, New York 14755.
Supporting Papers: Affirmation of Anne K. Bowling, Esq. with
attached Exhibits, dated November 19,2019.
Answering Papers: Pursuant to the agreement between the Court and the
parties, Defendants' responding papers must be filed on
or before November 27,2019; Plaintiffs' reply must be
filed on or before December 3,2019.
1 of 2
FILED: CATTARAUGUS COUNTY CLERK 11/27/2019 12:22 PM INDEX NO. 86157
NYSCEF DOC. NO. 3 RECEIVED NYSCEF: 11/27/2019
Relief Requested: An Order that Evans Land Corporation hold a
meeting of its shareholders on or before
December 31, 2019and an Order enjoining
Defendants from alienating any corporate assets
until such shareholder meeting is held, and for such
other and further relief as to the Court may seem
just and proper.
Grounds for Relief: New York Business Corporation Law.
Oral ArgUment: Requested and scheduled for December 5,2019.
Dated: November 19,2019
Buffalo, New York
RUPP BAASE PFALZGRAF
. CU NGHAM LLC
Att, eys for P~a~ ,',
. By'!' /hL" K · ~1~-lI
Anne K. Bowling, Esq. ,
1600 Liberty Building
Buffalo, New York 14202
(716) 854-3400
bowling@ruppbaase.com
TO: THE TARANTINO LAW FIRM LLP
Attorneys for Defendants
Jacob Piorkowski, Esq.
1500 Rand Building
Buffalo, New York 14203
(716) 262-9741
2 of 2
Document Filed Date
November 27, 2019
Case Filing Date
November 21, 2019
Category
Commercial - Contract
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FILED: CATTARAUGUS COUNTY CLERK 11/27/2019 12:22 PM INDEX NO. 86157 NYSCEF DOC. NO. 3 (" RECEIVED NYSCEF: 11/27/2019 STATE OF NEW YORK SUPREME COURT: COUNTY OF CATTARGUS ROBERT C. BEARDSLEY and ROBYN BEARDSLEY, Plaintiffs, Index No. 86157 v. -Index-Nu:-87-1-8'7- Hon. Jeremiah J. Moriarty III EVANS LAND CORPORATION and FREDERICK M. MANGUSO, Defendants .. NOTICE OF MOTION Nature of Action: Derivative suit. Moving Party: Plaintiffs. Directed To: Defendants. Date, Time and Place: December 5, 2019 at 9:30 a.m. before the Hon. Jeremiah J. Moriarty III, J~S.C., . 303 Court Street, 2nd Floor, Little Valley, New York 14755. Supporting Papers: Affirmation of Anne K. Bowling, Esq. with attached Exhibits, dated November 19,2019. Answering Papers: Pursuant to the agreement between the Court and the parties, Defendants' responding papers must be filed on or before November 27,2019; Plaintiffs' reply must be filed on or before December 3,2019. 1 of 2 FILED: CATTARAUGUS COUNTY CLERK 11/27/2019 12:22 PM INDEX NO. 86157 NYSCEF DOC. NO. 3 RECEIVED NYSCEF: 11/27/2019 Relief Requested: An Order that Evans Land Corporation hold a meeting of its shareholders on or before December 31, 2019and an Order enjoining Defendants from alienating any corporate assets until such shareholder meeting is held, and for such other and further relief as to the Court may seem just and proper. Grounds for Relief: New York Business Corporation Law. Oral ArgUment: Requested and scheduled for December 5,2019. Dated: November 19,2019 Buffalo, New York RUPP BAASE PFALZGRAF . CU NGHAM LLC Att, eys for P~a~ ,', . By'!' /hL" K · ~1~-lI Anne K. Bowling, Esq. , 1600 Liberty Building Buffalo, New York 14202 (716) 854-3400 bowling@ruppbaase.com TO: THE TARANTINO LAW FIRM LLP Attorneys for Defendants Jacob Piorkowski, Esq. 1500 Rand Building Buffalo, New York 14203 (716) 262-9741 2 of 2