On July 17, 2019 a
Motion,Ex Parte
was filed
involving a dispute between
Liberty Mutual Insurance Company,
Lm General Insurance Company,
and
Acutus Rx, Llc,
Ak Global Supply Corp.,
Amro Care Pt, P.C.,
Ava Custom Supply Inc.,
Citimedical I, Pllc,
Harbor Medical Group Pc,
Kendon Thomas,
Lawrence Chiropractic Diagnostic Services,
Mauro Chiropractic P.C.,
Metro Pain Specialists Professional Corporation,
North Shore Home Care Services, Inc.,
Opus Psychological Services P.C.,
Prospect Chiropractic Pllc,
Si Acupuncture, Pc,
in the District Court of New York County.
Preview
FILED: NEW YORK COUNTY CLERK 08/14/2020 05:13 PM INDEX NO. 654092/2019
NYSCEF DOC. NO. 41 RECEIVED NYSCEF: 08/14/2020
The Law Office of Gabriel & Moroff PC
2 Lincoln Avenue, Suite 400
Rockville Centre, NY 11570
Tel: (516 388-7040
Arthur Gabriel, Esq.
Jason Moroff, Esq.
Joseph Padrucco, Esq.
James Hilmoe
Justin Rosenbaum, Esq.
Max Valerio, Esq.
Nicole Montrony, Esq.
AnneMarie Lanni, Esq.
John Fagan, Esq.
Aug. 14, 2020
New York State Supreme Court
County of New York
Attention: Motion Submission Part Clerk
Re: Case Name: LIBERTY MUTUAL INSURANCE COMPANY et al v.
KENDON THOMAS et al
Index #: 654092/2019
File Number: DJ20-00644 DJ20-00645
Dear Sir/Madam:
We represent AVA CUSTOM SUPPLY INC in the above refenced litigation.
We respectfully request that the Plaintiffs’ motion for default judgment returnable, first time, on
8/17/20 be adjourned to 9/18/2020, the date that the court adjourned this matter to.
This is the first time the motion has been on and due to an unusually large volume of motions and
appearances I need the aforesaid adjournment to submit opposition. I was unable to obtain a
stipulation as to this matter due to time constraints of making this application.
Thank you for your consideration in this matter. If you have any questions regarding this matter,
please do not hesitate to contact us.
Yours truly,
Joseph J Padrucco
JOSPEH PADRUCCO ESQ.
cc: Asher Grossman, Esq. (via email)
BURKE, CONWAY & STIEFELD
Attorneys for Plaintiffs
LIBERTY MUTUAL INSURANCE COMPANY, ET AL
10 Bank Street - Suite 1200 White Plains, NY 10606
1 of 1
Document Filed Date
August 14, 2020
Case Filing Date
July 17, 2019
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FILED: NEW YORK COUNTY CLERK 08/14/2020 05:13 PM INDEX NO. 654092/2019 NYSCEF DOC. NO. 41 RECEIVED NYSCEF: 08/14/2020 The Law Office of Gabriel & Moroff PC 2 Lincoln Avenue, Suite 400 Rockville Centre, NY 11570 Tel: (516 388-7040 Arthur Gabriel, Esq. Jason Moroff, Esq. Joseph Padrucco, Esq. James Hilmoe Justin Rosenbaum, Esq. Max Valerio, Esq. Nicole Montrony, Esq. AnneMarie Lanni, Esq. John Fagan, Esq. Aug. 14, 2020 New York State Supreme Court County of New York Attention: Motion Submission Part Clerk Re: Case Name: LIBERTY MUTUAL INSURANCE COMPANY et al v. KENDON THOMAS et al Index #: 654092/2019 File Number: DJ20-00644 DJ20-00645 Dear Sir/Madam: We represent AVA CUSTOM SUPPLY INC in the above refenced litigation. We respectfully request that the Plaintiffs’ motion for default judgment returnable, first time, on 8/17/20 be adjourned to 9/18/2020, the date that the court adjourned this matter to. This is the first time the motion has been on and due to an unusually large volume of motions and appearances I need the aforesaid adjournment to submit opposition. I was unable to obtain a stipulation as to this matter due to time constraints of making this application. Thank you for your consideration in this matter. If you have any questions regarding this matter, please do not hesitate to contact us. Yours truly, Joseph J Padrucco JOSPEH PADRUCCO ESQ. cc: Asher Grossman, Esq. (via email) BURKE, CONWAY & STIEFELD Attorneys for Plaintiffs LIBERTY MUTUAL INSURANCE COMPANY, ET AL 10 Bank Street - Suite 1200 White Plains, NY 10606 1 of 1