On July 17, 2019 a
Motion,Ex Parte
was filed
involving a dispute between
American Transit Insurance Company,
and
Bradley Wasserman, Md, Pllc A O Jian-Cheng Dang,
Citimed Services, Pa,
Health Plus Surgery Center, Llc,
for Special Proceedings - Other (Arbitration Denovo)
in the District Court of New York County.
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FILED: NEW YORK COUNTY CLERK 08/15/2019 06:32 PM INDEX NO. 156988/2019
NYSCEF DOC. NO. 5 RECEIVED NYSCEF: 08/15/2019
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF NEW YORK
______________________________________________
AMERICAN TRANSIT INSURANCE COMPANY,
NOTICE OF MOTION
Plaintiff
-against -
Index No.: 156988/2019
HEALTH PLUS SURGERY CENTER, LLC,
CITIMED SERVICES, PA, and
BRADLEY WASSERMAN, MD, PLLC
A/0 JIAN-CHENG DANG,
Defendants.
_________________________________________________
COUNSELORS:
PLEASE TAKE NOTICE, that upon the affirmation of RACHEL DRACHMAN, ESQ.
dated September 20, 2019, and the attached Exhibits and upon the Summons and Complaint, and
all of the pleadings and proceedings herein, the undersigned will move this Supreme Court of the
State of New York at the County courthouse, 60 Centre Street, New York, New York 10013,
County of New York, New York on the 20th day of September, 2019, at 9:30 A.M., in Room 130
thereat, of that day or as soon thereafter as counsel can be heard for an order.
1. Pursuant to C.P.L.R. 3212 granting Summary Judgment to Defendant CITIMED
SERVICES, PA as there exists no substantive triable issue of fact, the matter is ripe
for determination on the law and
2. Granting such other and further relief that this Court deems just and proper.
PLEASE TAKE FURTHER NOTICE, that pursuant to CPLR 2214(b) answering
affidavits, if any, are to be served upon the undersigned no later than seven (7) days prior to the
return date of this motion.
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FILED: NEW YORK COUNTY CLERK 08/15/2019 06:32 PM INDEX NO. 156988/2019
NYSCEF DOC. NO. 5 RECEIVED NYSCEF: 08/15/2019
Dated: Richmond Hill, New York
August 7, 2019
Respectfully submitted,
_____________________________
Rachel Drachman, Esq.
Drachman Katz LLP
115-06 Myrtle Avenue
Richmond Hill, NY 11418
718-407-2411
To: SHORT & BILLY PC
Attorneys for Plaintiff
217 Broadway, Suite 300
New York, NY 10007
(212) 732-3320
2 of 2
Document Filed Date
August 15, 2019
Case Filing Date
July 17, 2019
Category
Special Proceedings - Other (Arbitration Denovo)
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FILED: NEW YORK COUNTY CLERK 08/15/2019 06:32 PM INDEX NO. 156988/2019 NYSCEF DOC. NO. 5 RECEIVED NYSCEF: 08/15/2019 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF NEW YORK ______________________________________________ AMERICAN TRANSIT INSURANCE COMPANY, NOTICE OF MOTION Plaintiff -against - Index No.: 156988/2019 HEALTH PLUS SURGERY CENTER, LLC, CITIMED SERVICES, PA, and BRADLEY WASSERMAN, MD, PLLC A/0 JIAN-CHENG DANG, Defendants. _________________________________________________ COUNSELORS: PLEASE TAKE NOTICE, that upon the affirmation of RACHEL DRACHMAN, ESQ. dated September 20, 2019, and the attached Exhibits and upon the Summons and Complaint, and all of the pleadings and proceedings herein, the undersigned will move this Supreme Court of the State of New York at the County courthouse, 60 Centre Street, New York, New York 10013, County of New York, New York on the 20th day of September, 2019, at 9:30 A.M., in Room 130 thereat, of that day or as soon thereafter as counsel can be heard for an order. 1. Pursuant to C.P.L.R. 3212 granting Summary Judgment to Defendant CITIMED SERVICES, PA as there exists no substantive triable issue of fact, the matter is ripe for determination on the law and 2. Granting such other and further relief that this Court deems just and proper. PLEASE TAKE FURTHER NOTICE, that pursuant to CPLR 2214(b) answering affidavits, if any, are to be served upon the undersigned no later than seven (7) days prior to the return date of this motion. 1 of 2 FILED: NEW YORK COUNTY CLERK 08/15/2019 06:32 PM INDEX NO. 156988/2019 NYSCEF DOC. NO. 5 RECEIVED NYSCEF: 08/15/2019 Dated: Richmond Hill, New York August 7, 2019 Respectfully submitted, _____________________________ Rachel Drachman, Esq. Drachman Katz LLP 115-06 Myrtle Avenue Richmond Hill, NY 11418 718-407-2411 To: SHORT & BILLY PC Attorneys for Plaintiff 217 Broadway, Suite 300 New York, NY 10007 (212) 732-3320 2 of 2