Motion,Ex Parte: Charles Bouille v. City Of New York, The New York City Department Of Education, Frank J. Macchiarola Educational Complex A/K/A New Visions Charter School A/K/A New Visions Charter High School For The Humanities Iii A/K/A Origins High School A/K/A K611

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                                FILED: KINGS COUNTY CLERK 12/16/2019 03:05 PM                                                      INDEX NO. 521848/2018
NYSCEF DOC. NO. 12                                                                          RECEIVED NYSCEF: 12/16/2019




          SUPREME COURT OF THE STATE OF NEW YORK
          COUNTY OF KINGS
          -----------------------------------------------------------------------X
          CHARLES BOUILLE,

                                                      Plaintiff,                     Index No. 521848/2018

                           -against-
                                                                                     NOTICE OF MOTION
          CITY OF NEW YORK, THE DEPARTMENT OF
          EDUCATION OF THE CITY OF NEW YORK and
          NEW VISIONS FOR PUBLIC SCHOOLS, INC. d/b/a
          NEW VISIONS CHARTER SCHOOLS,

                                                       Defendants.
          -------------------------------------------------------------------X

          COUNSEL:

                  PLEASE TAKE NOTICE that upon the annexed affirmation of Mark Salem, Esq., dated

          December 16, 2019; the exhibits annexed thereto; and upon the pleadings and proceedings

          heretofore had herein, the Plaintiff will move this Court, at the Courthouse located at 360 Adams

          Street, Brooklyn, NY 11201, in the Centralized Motion Part, on the 8th day of January, 2020 at

          9:30 am of that day, or as soon thereafter as counsel can be heard, for an order:

                  a)       VACATING Plaintiff’s default on October 21, 2019;

                  b)       RESTORING this matter to active status;

                  c)       SETTING a date for a Preliminary Conference; and

                  d)       GRANTING such other and further relief as is just and proper under the

          circumstances.

                  PLEASE TAKE NOTICE, that answering papers, if any, are to be served at least seven (7)

          days prior to the return date of this motion.




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FILED: KINGS COUNTY CLERK 12/16/2019 03:05 PM                                  INDEX NO. 521848/2018
NYSCEF DOC. NO. 12                                                       RECEIVED NYSCEF: 12/16/2019




          Dated:   Brooklyn, New York
                   December 16, 2019
                                                   Respectfully submitted,



                                                   _____________________________
                                                   Mark Salem Law, P.C.
                                                   Attorneys for Plaintiff
                                                   1669 East 10th Street
                                                   Brooklyn, New York 11223
                                                   718-701-0120

          TO:

          Molod, Spitz & Desantis, P.C.
          1430 Broadway, 21st Floor
          New York, NY 10018

          Corporation Counsel
          100 Church Street
          New York, NY 10007




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FILED: KINGS COUNTY CLERK 12/16/2019 03:05 PM                                                      INDEX NO. 521848/2018
NYSCEF DOC. NO. 12                                                                          RECEIVED NYSCEF: 12/16/2019




          SUPREME COURT OF THE STATE OF NEW YORK
          COUNTY OF KINGS
          -----------------------------------------------------------------------X
          CHARLES BOUILLE,

                                                      Plaintiff,                     Index No. 521848/2018

                           -against-

          CITY OF NEW YORK, THE DEPARTMENT OF
          EDUCATION OF THE CITY OF NEW YORK and
          NEW VISIONS FOR PUBLIC SCHOOLS, INC. d/b/a
          NEW VISIONS CHARTER SCHOOLS

                                                       Defendants.
          -------------------------------------------------------------------X


                                  NOTICE OF MOTION AND SUPPORTING PAPERS

                                                  MARK SALEM LAW, P.C.
                                                    Attorneys for Plaintiff
                                                    1669 East 10th Street
                                                    Brooklyn, NY 11223
                                                        718-701-0120

          Pursuant to 22 N.Y.C.R.R. § 130-1.1, the undersigned, an attorney admitted to practice in the
          courts of New York State, certifies that upon information and belief and reasonable inquiry, the
          contentions contained in the annexed documents are not frivolous.

          Dated: December 16, 2019
                                                                     Signature: _____________________________
                                                                                Mark Salem




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