Preview
FILED: NEW YORK COUNTY CLERK 10/02/2020 02:12 PM INDEX NO. 152395/2020
NYSCEF DOC. NO. 6 RECEIVED NYSCEF: 10/02/2020
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF NEW YORK
------ -----------------X Index No.: 152395/2020
JONATHAN SCOTT FRANK and
CELESTE FRANK,
Plaintiffs,
-against-
NOTICE OF MOTION
MARK LYN and
CHRISTINE FERREIRA LYN
a/k/a CHRISTINE LYN,
Defendants.
------------------------------------------- ------X
PLEASE TAKE NOTICE that, on the annexed Affidavit of Plaintiff JONATHAN SCOTT
29*
FRANK duly sworn to the day of September, 2020, the Affirmation of Howard Stern, Esq., duly
29th
sworn to the day of September, 2020, on the Summons and Verified Complaint herein dated
February 28, 2020, and on allthe papers and proceedings had herein, an application will be made at a
Motion Term of this Court, Submissions Part, Room 130, at the Courthouse located at 60 Centre Street,
27*
in the County of New York, City and State of New York, on the day of October, 2020, at 9:30
o'clock in the forenoon of that day or as soon thereafter as counsel may be heard for an order:
1. ADJUDGING Defendants MARK LYN and CHRIST1NE FERREIRA LYN a/k/a
CHRISTINE LYN to be in default in appearing and answering the Summons and Verified Complaint
herein;
2. GRANTING Judgment in favor of Plaintiffs JONATHAN SCOTT FRANK and
CELESTE FRANK and as against Defendant MARK LYN and CHRISTINE FERREIRA LYN a/k/a
CHRISTINE LYN as set forth in the Verified Complaint, as follows:
a) Judgment against the Defendants MARK LYN and CHRISTINE FERREIRA
LYN a/k/a CHRISTINE LYN in the amount of TWENTY-ONE THOUSAND EIGHT HUNDRED
AND 00/100 DOLLARS ($21,800.00), with interest thereon from September 30, 2019, on the First
Cause of Action;
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FILED: NEW YORK COUNTY CLERK 10/02/2020 02:12 PM INDEX NO. 152395/2020
NYSCEF DOC. NO. 6 RECEIVED NYSCEF: 10/02/2020
b) Judgment against the Defendant MARK LYN in the amount of NINE
THOUSAND FOUR HUNDRED AND THIRTY-FIVE AND 24/100 DOLLARS ($9,435.24) on the
Second Cause of Action;
c) Judgment against the Defendant MARK LYN in the amount of ONE
THOUSAND N1NE HUNDRED AND 00/100 DOLLARS ($1,900.00) on the Third Cause of Action;
and
d) Such other and further relief as to the court may seem just and proper, together
with the costs and disbursements of this action;
or, in the alternative, SETTING this matter down for an inquest or an assessment of damages, on
the cause(s) of action set out in the Summons and Verified Complaint by a reference and for Judgment
as demanded in the said Summons and Verified Complaint; and
3. GRANTING Plaintiffs such other and further relief as to this Court may seem just and
proper.
PLEASE TAKE FURTHER NOTICE that any answering affidavits are required to be served on
the undersigned not less than seven (7) days prior to the return date herein.
Dated: White Plains, New York
October 1, 2020
LAW FFICE OF HOWARD STERN
HOWARD STEN, ESQ.
Attorney for Plaintiffs
2 William Street, Suite 509
White Plains, NY 10601
(914) 683-0505
To: MARK LYN
Defendant PRO SE
535 Valley Street, Apt. 2
Orange, NJ 07050
CHRISTINE FERREIRA LYN a/lda CHRISTINE LYN
Defendant PRO SE
5 Shrewsbury Lane
Fairport, NY 14450
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FILED: NEW YORK COUNTY CLERK 10/02/2020 02:12 PM INDEX NO. 152395/2020
NYSCEF DOC. NO. 6 RECEIVED NYSCEF: 10/02/2020
Index No.: 152395/2020
======== =======--=====
Notice of Entry SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF NEW YORK
PLEASE take notice that the within is a (certified)
----- - ----
true copy of a JONATHAN SCOTT FRANK and
duly entered in the office of the clerk of the within CELESTE FRANK,
named court on Plaintiffs,
-against-
Dated: Yours, etc.
Howard Stern MARK LYN and
Attorney for CHRISTINE FERREIRA LYN
2 William Street, Suite 509 a/1da CHRISTINE LYN, Defendants.
White Plains, NY 10601 ------ --- ---------
To:
Attorney for NOTICE OF MOTION
HOWARD STERN
Attorney for Plaintiffs
2 William Street, Suite 509
========= -----------
Notice of Settlement White Plains, NY 10601
(914) 683-0505
PLEASE take Notice that a
of which the within is a true copy will be presented
for settlement to the To:
at
Attorney(s) for
On - ----- --------- ---
Signature Rule (Rule 130-1.1-a)
Dated:
Yours, etc.
Howard Stern
Attorney for oward Stern
2 William Street, Suite 509
White Plains, NY 10601 Service of a copy of the within is hereby admitted
Dated:
To:- - - - -- -- - - - - - - - - - -- - - - --- - ----- -- -- -
Attorney for . Attorney(s) for
3 of 3
Preview
FILED: NEW YORK COUNTY CLERK 10/02/2020 02:12 PM INDEX NO. 152395/2020 NYSCEF DOC. NO. 6 RECEIVED NYSCEF: 10/02/2020 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF NEW YORK ------ -----------------X Index No.: 152395/2020 JONATHAN SCOTT FRANK and CELESTE FRANK, Plaintiffs, -against- NOTICE OF MOTION MARK LYN and CHRISTINE FERREIRA LYN a/k/a CHRISTINE LYN, Defendants. ------------------------------------------- ------X PLEASE TAKE NOTICE that, on the annexed Affidavit of Plaintiff JONATHAN SCOTT 29* FRANK duly sworn to the day of September, 2020, the Affirmation of Howard Stern, Esq., duly 29th sworn to the day of September, 2020, on the Summons and Verified Complaint herein dated February 28, 2020, and on allthe papers and proceedings had herein, an application will be made at a Motion Term of this Court, Submissions Part, Room 130, at the Courthouse located at 60 Centre Street, 27* in the County of New York, City and State of New York, on the day of October, 2020, at 9:30 o'clock in the forenoon of that day or as soon thereafter as counsel may be heard for an order: 1. ADJUDGING Defendants MARK LYN and CHRIST1NE FERREIRA LYN a/k/a CHRISTINE LYN to be in default in appearing and answering the Summons and Verified Complaint herein; 2. GRANTING Judgment in favor of Plaintiffs JONATHAN SCOTT FRANK and CELESTE FRANK and as against Defendant MARK LYN and CHRISTINE FERREIRA LYN a/k/a CHRISTINE LYN as set forth in the Verified Complaint, as follows: a) Judgment against the Defendants MARK LYN and CHRISTINE FERREIRA LYN a/k/a CHRISTINE LYN in the amount of TWENTY-ONE THOUSAND EIGHT HUNDRED AND 00/100 DOLLARS ($21,800.00), with interest thereon from September 30, 2019, on the First Cause of Action; 1 of 3 FILED: NEW YORK COUNTY CLERK 10/02/2020 02:12 PM INDEX NO. 152395/2020 NYSCEF DOC. NO. 6 RECEIVED NYSCEF: 10/02/2020 b) Judgment against the Defendant MARK LYN in the amount of NINE THOUSAND FOUR HUNDRED AND THIRTY-FIVE AND 24/100 DOLLARS ($9,435.24) on the Second Cause of Action; c) Judgment against the Defendant MARK LYN in the amount of ONE THOUSAND N1NE HUNDRED AND 00/100 DOLLARS ($1,900.00) on the Third Cause of Action; and d) Such other and further relief as to the court may seem just and proper, together with the costs and disbursements of this action; or, in the alternative, SETTING this matter down for an inquest or an assessment of damages, on the cause(s) of action set out in the Summons and Verified Complaint by a reference and for Judgment as demanded in the said Summons and Verified Complaint; and 3. GRANTING Plaintiffs such other and further relief as to this Court may seem just and proper. PLEASE TAKE FURTHER NOTICE that any answering affidavits are required to be served on the undersigned not less than seven (7) days prior to the return date herein. Dated: White Plains, New York October 1, 2020 LAW FFICE OF HOWARD STERN HOWARD STEN, ESQ. Attorney for Plaintiffs 2 William Street, Suite 509 White Plains, NY 10601 (914) 683-0505 To: MARK LYN Defendant PRO SE 535 Valley Street, Apt. 2 Orange, NJ 07050 CHRISTINE FERREIRA LYN a/lda CHRISTINE LYN Defendant PRO SE 5 Shrewsbury Lane Fairport, NY 14450 2 of 3 FILED: NEW YORK COUNTY CLERK 10/02/2020 02:12 PM INDEX NO. 152395/2020 NYSCEF DOC. NO. 6 RECEIVED NYSCEF: 10/02/2020 Index No.: 152395/2020 ======== =======--===== Notice of Entry SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF NEW YORK PLEASE take notice that the within is a (certified) ----- - ---- true copy of a JONATHAN SCOTT FRANK and duly entered in the office of the clerk of the within CELESTE FRANK, named court on Plaintiffs, -against- Dated: Yours, etc. Howard Stern MARK LYN and Attorney for CHRISTINE FERREIRA LYN 2 William Street, Suite 509 a/1da CHRISTINE LYN, Defendants. White Plains, NY 10601 ------ --- --------- To: Attorney for NOTICE OF MOTION HOWARD STERN Attorney for Plaintiffs 2 William Street, Suite 509 ========= ----------- Notice of Settlement White Plains, NY 10601 (914) 683-0505 PLEASE take Notice that a of which the within is a true copy will be presented for settlement to the To: at Attorney(s) for On - ----- --------- --- Signature Rule (Rule 130-1.1-a) Dated: Yours, etc. Howard Stern Attorney for oward Stern 2 William Street, Suite 509 White Plains, NY 10601 Service of a copy of the within is hereby admitted Dated: To:- - - - -- -- - - - - - - - - - -- - - - --- - ----- -- -- - Attorney for . Attorney(s) for 3 of 3