On June 25, 2019 a
Motion,Ex Parte
was filed
involving a dispute between
326 21St Street Llc,
and
328 21 St Llc,
Nyb Builders Inc.,
Regal Reconstruction Corp,
Zumbas Builders Inc,
for Torts - Other Negligence (Property Damage)
in the District Court of Kings County.
Preview
FILED: KINGS COUNTY CLERK 10/02/2019 04:27 PM INDEX NO. 514069/2019
NYSCEF DOC. NO. 7 RECEIVED NYSCEF: 10/02/2019
SUPREME COURT OF THE STATE OF NEW YORK Index No. 514069/2019
COUNTY OF KINGS
-----------------------------------------------------------X
326 21st STREET LLC, NOTICE OF MOTION
Plaintiff
-against-
328 21 ST LLC, NYB BUILDERS INC,
REGAL RECONSTRUCTION CORP.
Defendants
-----------------------------------------------------------X
MOVANT: Defendant, Regal Reconstruction Corp., by
their attorney, Erica D. Vitanza of The Law
Office of Thaniel J. Beinert & Associates
DATE, TIME, & PLACE: November 1, 2019, at 9:30 a.m. at the
Supreme Court, Kings County, located at
360 Adams Street, Brooklyn, NY 11201 IAS
part to be assigned, or as soon thereafter as
counsel can be heard.
ORAL ARGUMENT: Requested
RELIEF REQUESTED: An order pursuant to CPLR 3211 (a), (1)
and (7) dismissing the complainant in its
entirety and granting further relief as the
court deems just, proper, and equitable.
SUPPORRTING PAPERS: Affirmation of Erica D. Vitanza, Affidavit
of Regal Reconstruction Corp., and
supporting exhibits;
ANSWERING PAPERS: Under CPLR 2214 (b) answering papers, if
any should be served at least seven (7) days
prior to the return date of this motion
This action is not on the trial calendar.
No prior application has been made for similar relief.
1 of 3
FILED: KINGS COUNTY CLERK 10/02/2019 04:27 PM INDEX NO. 514069/2019
NYSCEF DOC. NO. 7 RECEIVED NYSCEF: 10/02/2019
Dated: Brooklyn, New York Yours, etc.
October 2, 2019
LAW OFFICE OF THANIEL J. BEINERT
& ASSOCIATES
Erica D. Vitanza
Attorney for Defendant, Regal
Reconstruction Corp.
155 Bay Ridge Ave
Brooklyn, New York 11220
(718) 921 – 6601
TO: Clerk of The Supreme Court, Kings County
Lerner, Arnold & Winston, LLP
By: Jacob L. Levine, Esq.
475 Park Avenue South, 28th Floor
New York, NY 10016
(212) 686-4655
Attorney for the Plaintiff
Koster, Brady & Nagler, LLP
By: Jason J. Lavery, Esq.
One Whitehall Street, 10th Floor
New York, NY 10004
(212) 248-8800
Attorneys for Defendant, 328 21 ST LLC
NYB Builders, Inc.
c/o NYS Division of Corporations
2 of 3
FILED: KINGS COUNTY CLERK 10/02/2019 04:27 PM INDEX NO. 514069/2019
NYSCEF DOC. NO. 7 RECEIVED NYSCEF: 10/02/2019
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF KINGS INDEX NO.: 514069/2019
326 21st STREET LLC,
Plaintiff
-against-
328 21 ST LLC, NYB BUILDERS INC,
REGAL RECONSTRUCTION CORP.
Defendants
NOTICE OF MOTION
LAW OFFICE OF THANIEL J. BEINERT
ATTORNEY FOR DEFENDANT
155 BAY RIDGE AVENUE
BROOKLYN, NEW YORK 11220
718-921-6601
TO: SERVICE OF A COPY OF THE WITHIN
IS HEREBY ADMITTED.
DATED: 20
ATTORNEY(s) for Plaintiff(s)
PLEASE TAKE NOTICE:
NOTICE OF ENTRY
that the within is a (certified) true copy of a
duly entered in the office of the clerk of the within named court on
NOTICE OF SETTLEMENT
that an order
of which 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 at AM.
DATED: Yours, etc.
The Law Office of Thaniel J. Beinert
3 of 3
Document Filed Date
October 02, 2019
Case Filing Date
June 25, 2019
Category
Torts - Other Negligence (Property Damage)
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FILED: KINGS COUNTY CLERK 10/02/2019 04:27 PM INDEX NO. 514069/2019 NYSCEF DOC. NO. 7 RECEIVED NYSCEF: 10/02/2019 SUPREME COURT OF THE STATE OF NEW YORK Index No. 514069/2019 COUNTY OF KINGS -----------------------------------------------------------X 326 21st STREET LLC, NOTICE OF MOTION Plaintiff -against- 328 21 ST LLC, NYB BUILDERS INC, REGAL RECONSTRUCTION CORP. Defendants -----------------------------------------------------------X MOVANT: Defendant, Regal Reconstruction Corp., by their attorney, Erica D. Vitanza of The Law Office of Thaniel J. Beinert & Associates DATE, TIME, & PLACE: November 1, 2019, at 9:30 a.m. at the Supreme Court, Kings County, located at 360 Adams Street, Brooklyn, NY 11201 IAS part to be assigned, or as soon thereafter as counsel can be heard. ORAL ARGUMENT: Requested RELIEF REQUESTED: An order pursuant to CPLR 3211 (a), (1) and (7) dismissing the complainant in its entirety and granting further relief as the court deems just, proper, and equitable. SUPPORRTING PAPERS: Affirmation of Erica D. Vitanza, Affidavit of Regal Reconstruction Corp., and supporting exhibits; ANSWERING PAPERS: Under CPLR 2214 (b) answering papers, if any should be served at least seven (7) days prior to the return date of this motion This action is not on the trial calendar. No prior application has been made for similar relief. 1 of 3 FILED: KINGS COUNTY CLERK 10/02/2019 04:27 PM INDEX NO. 514069/2019 NYSCEF DOC. NO. 7 RECEIVED NYSCEF: 10/02/2019 Dated: Brooklyn, New York Yours, etc. October 2, 2019 LAW OFFICE OF THANIEL J. BEINERT & ASSOCIATES Erica D. Vitanza Attorney for Defendant, Regal Reconstruction Corp. 155 Bay Ridge Ave Brooklyn, New York 11220 (718) 921 – 6601 TO: Clerk of The Supreme Court, Kings County Lerner, Arnold & Winston, LLP By: Jacob L. Levine, Esq. 475 Park Avenue South, 28th Floor New York, NY 10016 (212) 686-4655 Attorney for the Plaintiff Koster, Brady & Nagler, LLP By: Jason J. Lavery, Esq. One Whitehall Street, 10th Floor New York, NY 10004 (212) 248-8800 Attorneys for Defendant, 328 21 ST LLC NYB Builders, Inc. c/o NYS Division of Corporations 2 of 3 FILED: KINGS COUNTY CLERK 10/02/2019 04:27 PM INDEX NO. 514069/2019 NYSCEF DOC. NO. 7 RECEIVED NYSCEF: 10/02/2019 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF KINGS INDEX NO.: 514069/2019 326 21st STREET LLC, Plaintiff -against- 328 21 ST LLC, NYB BUILDERS INC, REGAL RECONSTRUCTION CORP. Defendants NOTICE OF MOTION LAW OFFICE OF THANIEL J. BEINERT ATTORNEY FOR DEFENDANT 155 BAY RIDGE AVENUE BROOKLYN, NEW YORK 11220 718-921-6601 TO: SERVICE OF A COPY OF THE WITHIN IS HEREBY ADMITTED. DATED: 20 ATTORNEY(s) for Plaintiff(s) PLEASE TAKE NOTICE: NOTICE OF ENTRY that the within is a (certified) true copy of a duly entered in the office of the clerk of the within named court on NOTICE OF SETTLEMENT that an order of which 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 at AM. DATED: Yours, etc. The Law Office of Thaniel J. Beinert 3 of 3