On August 04, 2014 a
Motion-Secondary
was filed
involving a dispute between
The New Hope Missionary Baptist Church, Inc.,
and
New York State Attorney General,
for Contract (Non-Commercial)
in the District Court of Kings County.
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(FILED: KINGS COUNTY CLERK 0472072015 05:19 PM INDEX NO. 507138/2014
NYSCEF DOC. NO. 21 RECEIVED NYSCEF: 04/20/2015
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF KINGS
ee x Index # 507138/14
In the Matter of the Application of
NOTICE OF MOTION
THE NEW HOPE MISSIONARY BAPTIST
CHURCH, INC., a Religious Corporation
Petitioner
to sell, transfer and Convey its Reai Properiy situate
in the County of Kings, State of New York.
x
PLEASE TAKE NOTICE that upon the attached Affidavit of MARJORIE BEECHER, for
herself and as officer of FAMEK MANAGEMENT CORP., the Exhibits and Proceedings
heretofore had herein, movant, MARJORIE BEECHER and FAMEK MANAGEMENT CORP.,
by its attorneys, C. STEVE OKENWA, P.C., will move this Court, located at 360 Adams Street,
Brooklyn, NY 11201, at Part 88, before Hon. Dawn Jimenez Salta, JSC., on the 30" of April,
2015. at 9.30 AM. or so soon thereafter as Counsel may be heard for an Order:
1. Pursuant to CPLR 1013 permitting FAMEK MANAGEMENT CORP. And MARJORIE
BEECHER. to intervene in the within action:
2. Upon intervention, staying petitioners’ application to sell the premises underlying this
action, namely. 319 Nostrand Avenue, Brooklyn. NY 11216, pending the determination of
movants’ application before Hon. Bernadette Baynes, JSC., in the matter under Index #
34774/08, seeking the vacatur of the judgment against movants;
3. Any other or further orders and reliefs as the court may deem fair and proper under the
circumstances.PLEASE TAKE FURTHER NOTICE, that pursuant to CPLR 2214(b) answering papers, if any,
are to be served at least seven(7) days before the return date hereof.
Dated: New York, New York
April 7, 2015
Tel. 646 845 7493
Attorneys for Movant
Document Filed Date
April 20, 2015
Case Filing Date
August 04, 2014
Category
Contract (Non-Commercial)
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(FILED: KINGS COUNTY CLERK 0472072015 05:19 PM INDEX NO. 507138/2014 NYSCEF DOC. NO. 21 RECEIVED NYSCEF: 04/20/2015 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF KINGS ee x Index # 507138/14 In the Matter of the Application of NOTICE OF MOTION THE NEW HOPE MISSIONARY BAPTIST CHURCH, INC., a Religious Corporation Petitioner to sell, transfer and Convey its Reai Properiy situate in the County of Kings, State of New York. x PLEASE TAKE NOTICE that upon the attached Affidavit of MARJORIE BEECHER, for herself and as officer of FAMEK MANAGEMENT CORP., the Exhibits and Proceedings heretofore had herein, movant, MARJORIE BEECHER and FAMEK MANAGEMENT CORP., by its attorneys, C. STEVE OKENWA, P.C., will move this Court, located at 360 Adams Street, Brooklyn, NY 11201, at Part 88, before Hon. Dawn Jimenez Salta, JSC., on the 30" of April, 2015. at 9.30 AM. or so soon thereafter as Counsel may be heard for an Order: 1. Pursuant to CPLR 1013 permitting FAMEK MANAGEMENT CORP. And MARJORIE BEECHER. to intervene in the within action: 2. Upon intervention, staying petitioners’ application to sell the premises underlying this action, namely. 319 Nostrand Avenue, Brooklyn. NY 11216, pending the determination of movants’ application before Hon. Bernadette Baynes, JSC., in the matter under Index # 34774/08, seeking the vacatur of the judgment against movants; 3. Any other or further orders and reliefs as the court may deem fair and proper under the circumstances.PLEASE TAKE FURTHER NOTICE, that pursuant to CPLR 2214(b) answering papers, if any, are to be served at least seven(7) days before the return date hereof. Dated: New York, New York April 7, 2015 Tel. 646 845 7493 Attorneys for Movant