Motion,Ex Parte: Kuan He Wu, Good Fortune Supermarket Of Elmhurst, Inc., Good Fortune Supermarket Of Nj, Inc., Good Fortune Supermarket Of Brooklyn, Inc. v. Sai Lu Pan, Li Hui Zhang
On September 19, 2013 a
Motion,Ex Parte
was filed
involving a dispute between
Good Fortune Supermarket Of Brooklyn, Inc.,
Good Fortune Supermarket Of Elmhurst, Inc.,
Good Fortune Supermarket Of Nj, Inc.,
Kuan He Wu,
and
Li Hui Zhang,
Sai Lu Pan,
for Tort
in the District Court of Kings County.
Preview
(FILED ED: KINGS COUNTY CLERK 03710/2014) rn O14) > Oo INDEX NO. 505568/2013
NYSCEF DOC. NO. 3 RECEIVED NYSCEF: 03/10/2014
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF KINGS
ween tenet nnn nnn cence nn tina nn nnn X Index No. 505568/2013
KUAN HE WU,GOOD FORTUNE SUPERMARKET OF
ELMHURST, INC., GOOD FORTUNE SUPERMARKET
OF NJ, INC., and GOOD FORTUNE SUPERMARKET NOTICE OF MOTION |
OF BROOKLYN, INC., ‘TO DISMISS ACTION
Plaintiffs,
-against-
SAI LU PAN and LI HUI ZHANG
Defendants.
ee ene nnn
PLEASE TAKE NOTICE that upon the annexed affirmation of Jeremy B. Honig, Esq.,
dated March 7, 2014, the exhibits annexed thereto, and upon all papers and proceedings
heretofore had herein, the defendants, Sai Lu Pan (“Defendants”) will move this Court at an LAS
Part, 360 Adams Street, Brooklyn, NY 11201 on the 18" day of April, 2014 at 9:30 o’clock on
the forenoon of that day or as soon thereafter as counsel can be heard for an Order (a) dismissing
the Plaintiffs’ Complaint pursuant to CPLR §306-b and §308(2); or, in the alternative (b)
transferring this action to Supreme Court, New York County upon the grounds that the parties
agreed in writing that any action would be commenced in Supreme Court, New York County; (c)
along with such other and further relief as this Court deems just and proper.
PLEASE TAKE FURTHER NOTICE that any answering papers and/or any cross-
motions shall be served upon the attorney for Defendants no later than seven (7) days prior to the
return date of this motion.
163737-1Dated: March 7, 2014
New York, New York
To:
Xie & Associates, PLLC
Attorneys for Plaintiffs
401 Broadway, Suite 1010
New York, NY 10013
(212) 226-0188
Attn: Russel L. Porter, Esq.
163737-1
Yours, etc.
JAFFE ae & LIGHT LLP
ihe
"eS B. Honig
attomnd far Defendant-SAI LU
PAN
880 Third Ave.
New York, New York 10022
(212) 751-1700
Preview
(FILED ED: KINGS COUNTY CLERK 03710/2014) rn O14) > Oo INDEX NO. 505568/2013 NYSCEF DOC. NO. 3 RECEIVED NYSCEF: 03/10/2014 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF KINGS ween tenet nnn nnn cence nn tina nn nnn X Index No. 505568/2013 KUAN HE WU,GOOD FORTUNE SUPERMARKET OF ELMHURST, INC., GOOD FORTUNE SUPERMARKET OF NJ, INC., and GOOD FORTUNE SUPERMARKET NOTICE OF MOTION | OF BROOKLYN, INC., ‘TO DISMISS ACTION Plaintiffs, -against- SAI LU PAN and LI HUI ZHANG Defendants. ee ene nnn PLEASE TAKE NOTICE that upon the annexed affirmation of Jeremy B. Honig, Esq., dated March 7, 2014, the exhibits annexed thereto, and upon all papers and proceedings heretofore had herein, the defendants, Sai Lu Pan (“Defendants”) will move this Court at an LAS Part, 360 Adams Street, Brooklyn, NY 11201 on the 18" day of April, 2014 at 9:30 o’clock on the forenoon of that day or as soon thereafter as counsel can be heard for an Order (a) dismissing the Plaintiffs’ Complaint pursuant to CPLR §306-b and §308(2); or, in the alternative (b) transferring this action to Supreme Court, New York County upon the grounds that the parties agreed in writing that any action would be commenced in Supreme Court, New York County; (c) along with such other and further relief as this Court deems just and proper. PLEASE TAKE FURTHER NOTICE that any answering papers and/or any cross- motions shall be served upon the attorney for Defendants no later than seven (7) days prior to the return date of this motion. 163737-1Dated: March 7, 2014 New York, New York To: Xie & Associates, PLLC Attorneys for Plaintiffs 401 Broadway, Suite 1010 New York, NY 10013 (212) 226-0188 Attn: Russel L. Porter, Esq. 163737-1 Yours, etc. JAFFE ae & LIGHT LLP ihe "eS B. Honig attomnd far Defendant-SAI LU PAN 880 Third Ave. New York, New York 10022 (212) 751-1700