On July 17, 2019 a
Motion,Ex Parte
was filed
involving a dispute between
Anelfa P. Gonzalez,
and
2705 & 2707 Morris Llc,
City Skyline Realty, Inc.,
for Torts - Other Negligence (Premises Liability)
in the District Court of New York County.
Preview
FILED: NEW YORK COUNTY CLERK 12/23/2019 02:51 PM INDEX NO. 156998/2019
NYSCEF DOC. NO. 8 RECEIVED NYSCEF: 12/23/2019
SUPREME COURT: STATE OF NEW YORK
COUNTY OF NEW YORK
--------------------· ---------------------------------------X
ANELF AP. GONZALEZ, Index No.: 156998/2019
Plaintiff, NOTICE OF MOTION
-against- Return Date:
January 29, 2020
2705 & 2707 MORRIS LLC and CITY SKYLINE
REALTY, INC., Judge: Honorable
Barbara Jaffe
Defendants.
-· ---------------- ----- ------------------------------------X
COUNSEL:
PLEASE TAKE NOTICE, that upon the annexed Affinnation of LAURA ASHLEY
MARTIN, ESQ. affirmed on the 19th day of December, 2019, the exhibits annexed hereto, and
upon all the pleadings and proceedings heretofore had herein, the undersigned will move this court
at the Supreme Court of the State of New York, County of New York before the Motion
Submission Part Courtroom, Room 130, at the Courthouse located at 60 Centre Street, New York,
10007 on the 29th day of January, 2020 at 9:30 a.m. in the forenoon of that day, or as soon
thereafter as Counsel may be heard, for an Order:
a) pursuant to CPLR §3124 and §3126, striking Plaintiffs Complaint and dismissing the
action due to Plaintiffs continued failure to provide Court Ordered discovery responses; or
b) precluding Plaintiff from offering any evidence supporting the allegations in Plaintiff's
Complaint; or
c) in the alternative, compelling Plaintiff to provide complete and proper responses to
Defendants' Discovery Demands, together with such other and further relief as this Court deems
just and proper.
1 of 2
FILED: NEW YORK COUNTY CLERK 12/23/2019 02:51 PM INDEX NO. 156998/2019
NYSCEF DOC. NO. 8 RECEIVED NYSCEF: 12/23/2019
PLEASE TAKE FURTHER NOTICE, that pursuant to CPLR §2214(b), answering
affidavits if any shall be served at least seven (7) days in advance of the return date hereof.
Dated: White Plains, New York
December 19, 2019
shley Martin, Esq.
Attorneys for Defendants
2705 & 2707 Morris LLC and City Skyline
Realty, Inc.
150 Grand Street, Suite 610
White Plains, New York 10601
(914) 505-6283
GCKB File No.: 1043.0023
TO: LAW OFFICES OF AMI MORGENSTERN
Adam S. Ashe, Esq.
Attorneys for Plaintiff
40-17 Broadway, 2nd Floor
P.O. Box 3223
Long Island City, New York 11103-0223
718-777-9595
2 of 2
Document Filed Date
December 23, 2019
Case Filing Date
July 17, 2019
Category
Torts - Other Negligence (Premises Liability)
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Preview
FILED: NEW YORK COUNTY CLERK 12/23/2019 02:51 PM INDEX NO. 156998/2019 NYSCEF DOC. NO. 8 RECEIVED NYSCEF: 12/23/2019 SUPREME COURT: STATE OF NEW YORK COUNTY OF NEW YORK --------------------· ---------------------------------------X ANELF AP. GONZALEZ, Index No.: 156998/2019 Plaintiff, NOTICE OF MOTION -against- Return Date: January 29, 2020 2705 & 2707 MORRIS LLC and CITY SKYLINE REALTY, INC., Judge: Honorable Barbara Jaffe Defendants. -· ---------------- ----- ------------------------------------X COUNSEL: PLEASE TAKE NOTICE, that upon the annexed Affinnation of LAURA ASHLEY MARTIN, ESQ. affirmed on the 19th day of December, 2019, the exhibits annexed hereto, and upon all the pleadings and proceedings heretofore had herein, the undersigned will move this court at the Supreme Court of the State of New York, County of New York before the Motion Submission Part Courtroom, Room 130, at the Courthouse located at 60 Centre Street, New York, 10007 on the 29th day of January, 2020 at 9:30 a.m. in the forenoon of that day, or as soon thereafter as Counsel may be heard, for an Order: a) pursuant to CPLR §3124 and §3126, striking Plaintiffs Complaint and dismissing the action due to Plaintiffs continued failure to provide Court Ordered discovery responses; or b) precluding Plaintiff from offering any evidence supporting the allegations in Plaintiff's Complaint; or c) in the alternative, compelling Plaintiff to provide complete and proper responses to Defendants' Discovery Demands, together with such other and further relief as this Court deems just and proper. 1 of 2 FILED: NEW YORK COUNTY CLERK 12/23/2019 02:51 PM INDEX NO. 156998/2019 NYSCEF DOC. NO. 8 RECEIVED NYSCEF: 12/23/2019 PLEASE TAKE FURTHER NOTICE, that pursuant to CPLR §2214(b), answering affidavits if any shall be served at least seven (7) days in advance of the return date hereof. Dated: White Plains, New York December 19, 2019 shley Martin, Esq. Attorneys for Defendants 2705 & 2707 Morris LLC and City Skyline Realty, Inc. 150 Grand Street, Suite 610 White Plains, New York 10601 (914) 505-6283 GCKB File No.: 1043.0023 TO: LAW OFFICES OF AMI MORGENSTERN Adam S. Ashe, Esq. Attorneys for Plaintiff 40-17 Broadway, 2nd Floor P.O. Box 3223 Long Island City, New York 11103-0223 718-777-9595 2 of 2