Preview
FILED: NEW YORK COUNTY CLERK 04/16/2021 08:25 AM INDEX NO. 151434/2020
NYSCEF DOC. NO. 39 RECEIVED NYSCEF: 04/21/2021
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF NEW YORK
----------------------------------------------------------------------------------------------------------------------X
ALLSTATE INDEMNITY COMPANY AS NOTICE OF MOTION FOR
SUBROGEE OF SWAROOPA REDDY DESAI, DEFAULT JUDGMENT
Plaintiff, Index No. 151434/20
vs. Return Date: May 18, 2021
JMJ TURTLE BAY HOLDINGS, LLC, DENNIS
PERTROCELLI, RUBIN MENG, ANTHONY
PANTALEONI, GENESIS WILSON, THE
RELATED COMPANY and RELATED
MANAGEMENT,
Defendants.
---------------------------------------------------------------------------------------------------------------------X
SIRS:
PLEASE TAKE NOTICE, that upon the annexed affirmation of STEVE
SOPHOCLEOUS, ESQUIRE, dated April 8, 2021, together with the annexed exhibits, and upon
the proceedings heretofore had herein, the undersigned will move this Court at a Motion
Submission Part, Room 130, to be held at the Courthouse located at 60 Centre Street, New
York, New York, on May 18, 2021 at 9:30 o'clock in the forenoon of that day, or as soon
thereafter as Counsel may be heard, for an order, pursuant to CPLR §3215(a)(b), directing that a
Default Judgment be entered against Defendant(s), ANTHONY PANTALEONI AND RUBIN
MENG, or in the alternative, setting this matter down for an inquest in favor of the Plaintiff,
assessing damages in a sum certain or for a sum which can, by computation, be made certain,
awarding costs and fees to Plaintiff’s attorneys, and for such other and further relief as to this
Court seems just and proper.
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FILED: NEW YORK COUNTY CLERK 04/16/2021 08:25 AM INDEX NO. 151434/2020
NYSCEF DOC. NO. 39 RECEIVED NYSCEF: 04/21/2021
PLEASE TAKE FURTHER NOTICE, that answering affidavits, if any, are to
be served upon the undersigned within seven (7) days prior to the return date of the within
application.
DATED: Brooklyn, New York
April 08, 2021
LAW OFFICES OF KAREN L. LAWRENCE
By:
Steve Sophocleous, Esquire
4 Metrotech Center, Suite 2000
Brooklyn, NY 11201-3815
Telephone:718-451-7106
Our File No. 0445814114.1-
TO: ANTHONY PANTALEONI
PRO-SE DEFENDANT
250 E. 53RD STREET, APT 2902
NEW YORK, NY 10022
RUBIN MENG
PRO-SE DEFENDANT
250 E. 53RD STREET, APT 2902
NEW YORK, NY 10022
LAW OFFICE OF JAMES J. TOOMEY
ATTORNEYS FOR DEFENDANTS
JMJ TURTLE BAY HOLDINGS, LLC AND DENNIS PERTROCELLI
PO BOX 2903
HARTFORD, CT 06104-2903
FILE NO. 2020022935
HICKEY SMITH LLP
ATTORNEYS FOR DEFENDANTS
THE RELATED COMPANY and RELATED MANAGEMENT
1040 AVENUE OF THE AMERICAS, SUITE 9C
NEW YORK, NY 10018
FILE NO. 4721
KOWALSKI & DEVITO
ATTORNEYS FOR DEFENDANT GENESIS WILSON
80 PINE STREET, SUITE 300
NEW YORK, NY 10005
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FILED: NEW YORK COUNTY CLERK 04/16/2021 08:25 AM INDEX NO. 151434/2020
NYSCEF DOC. NO. 39 RECEIVED NYSCEF: 04/21/2021
FILE NO. NYNY-33802
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FILED: NEW YORK COUNTY CLERK 04/16/2021 08:25 AM INDEX NO. 151434/2020
NYSCEF DOC. NO. 39 RECEIVED NYSCEF: 04/21/2021
AFFIDAVIT OF SERVICE BY MAIL
STATE OF NEW YORK )
) ss:
COUNTY OF KINGS )
/Wic/Mit /4 yo»fw r , being duly sworn, deposes and says, that the deponent is not a
party to the action herein, and is a Paralegal for the LAW OFFICES OF KAREN L.
LAWRENCE, the attorney for the within named Plaintiff, ALLSTATE INDEMNITY
COMPANY AS SUBROGEE OF SWAROOPA REDDY DESAI. That on
/##A 7/ , deponent served the within NOTICE OF MOTION FOR
2s/
DEFAULT by depositing a true copy of the same securely enclosed in a post-paid wrapper in a
Post Office Box regularly maintained by the United States Government at 4 Metrotech Center,
Suite 2000, Brooklyn, in the County of KINGS, State of New York, directed to:
ANTHONY PANTALEONI HICKEY SMITH LLP
250 E. 53RD STREET, APT 2902 1040 AVENUE OF THE AMERICAS, SUITE 9C
NEW YORK, NY 10022 NEW YORK, NY 10018
RUBIN MENG KOWALSKI & DEVITO
250 E. 53RD STREET, APT 2902 80 P1NE STREET, SU1TE 300
NEW YORK, NY 10022 NEW YORK, NY 10005
LAW OFFICE OF JAMES J.TOOMEY
PO BOX 2903
HARTFORD, CT 06104-2903
that being the address(s) within the state designated by the deponent for that purpose upon the
preceding papers in this action, or the place where deponent then kept an office, between which
places there then was and now is a regular communication by mail. Electroñic Service could not
be effecMated as unrepresented party has no electronic means of service known to your
affirmant.
Deponent is over the age of eighteen (18) years.
vtatt-/ MHL Ho y
Our File No. 0445814114.1-
Subscribed and sworn to before me this
2-r day of , 2021.
Notary Public
My Cceslssian Expires: 2p2L
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Preview
FILED: NEW YORK COUNTY CLERK 04/16/2021 08:25 AM INDEX NO. 151434/2020 NYSCEF DOC. NO. 39 RECEIVED NYSCEF: 04/21/2021 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF NEW YORK ----------------------------------------------------------------------------------------------------------------------X ALLSTATE INDEMNITY COMPANY AS NOTICE OF MOTION FOR SUBROGEE OF SWAROOPA REDDY DESAI, DEFAULT JUDGMENT Plaintiff, Index No. 151434/20 vs. Return Date: May 18, 2021 JMJ TURTLE BAY HOLDINGS, LLC, DENNIS PERTROCELLI, RUBIN MENG, ANTHONY PANTALEONI, GENESIS WILSON, THE RELATED COMPANY and RELATED MANAGEMENT, Defendants. ---------------------------------------------------------------------------------------------------------------------X SIRS: PLEASE TAKE NOTICE, that upon the annexed affirmation of STEVE SOPHOCLEOUS, ESQUIRE, dated April 8, 2021, together with the annexed exhibits, and upon the proceedings heretofore had herein, the undersigned will move this Court at a Motion Submission Part, Room 130, to be held at the Courthouse located at 60 Centre Street, New York, New York, on May 18, 2021 at 9:30 o'clock in the forenoon of that day, or as soon thereafter as Counsel may be heard, for an order, pursuant to CPLR §3215(a)(b), directing that a Default Judgment be entered against Defendant(s), ANTHONY PANTALEONI AND RUBIN MENG, or in the alternative, setting this matter down for an inquest in favor of the Plaintiff, assessing damages in a sum certain or for a sum which can, by computation, be made certain, awarding costs and fees to Plaintiff’s attorneys, and for such other and further relief as to this Court seems just and proper. 1 of 4 FILED: NEW YORK COUNTY CLERK 04/16/2021 08:25 AM INDEX NO. 151434/2020 NYSCEF DOC. NO. 39 RECEIVED NYSCEF: 04/21/2021 PLEASE TAKE FURTHER NOTICE, that answering affidavits, if any, are to be served upon the undersigned within seven (7) days prior to the return date of the within application. DATED: Brooklyn, New York April 08, 2021 LAW OFFICES OF KAREN L. LAWRENCE By: Steve Sophocleous, Esquire 4 Metrotech Center, Suite 2000 Brooklyn, NY 11201-3815 Telephone:718-451-7106 Our File No. 0445814114.1- TO: ANTHONY PANTALEONI PRO-SE DEFENDANT 250 E. 53RD STREET, APT 2902 NEW YORK, NY 10022 RUBIN MENG PRO-SE DEFENDANT 250 E. 53RD STREET, APT 2902 NEW YORK, NY 10022 LAW OFFICE OF JAMES J. TOOMEY ATTORNEYS FOR DEFENDANTS JMJ TURTLE BAY HOLDINGS, LLC AND DENNIS PERTROCELLI PO BOX 2903 HARTFORD, CT 06104-2903 FILE NO. 2020022935 HICKEY SMITH LLP ATTORNEYS FOR DEFENDANTS THE RELATED COMPANY and RELATED MANAGEMENT 1040 AVENUE OF THE AMERICAS, SUITE 9C NEW YORK, NY 10018 FILE NO. 4721 KOWALSKI & DEVITO ATTORNEYS FOR DEFENDANT GENESIS WILSON 80 PINE STREET, SUITE 300 NEW YORK, NY 10005 2 of 4 FILED: NEW YORK COUNTY CLERK 04/16/2021 08:25 AM INDEX NO. 151434/2020 NYSCEF DOC. NO. 39 RECEIVED NYSCEF: 04/21/2021 FILE NO. NYNY-33802 3 of 4 FILED: NEW YORK COUNTY CLERK 04/16/2021 08:25 AM INDEX NO. 151434/2020 NYSCEF DOC. NO. 39 RECEIVED NYSCEF: 04/21/2021 AFFIDAVIT OF SERVICE BY MAIL STATE OF NEW YORK ) ) ss: COUNTY OF KINGS ) /Wic/Mit /4 yo»fw r , being duly sworn, deposes and says, that the deponent is not a party to the action herein, and is a Paralegal for the LAW OFFICES OF KAREN L. LAWRENCE, the attorney for the within named Plaintiff, ALLSTATE INDEMNITY COMPANY AS SUBROGEE OF SWAROOPA REDDY DESAI. That on /##A 7/ , deponent served the within NOTICE OF MOTION FOR 2s/ DEFAULT by depositing a true copy of the same securely enclosed in a post-paid wrapper in a Post Office Box regularly maintained by the United States Government at 4 Metrotech Center, Suite 2000, Brooklyn, in the County of KINGS, State of New York, directed to: ANTHONY PANTALEONI HICKEY SMITH LLP 250 E. 53RD STREET, APT 2902 1040 AVENUE OF THE AMERICAS, SUITE 9C NEW YORK, NY 10022 NEW YORK, NY 10018 RUBIN MENG KOWALSKI & DEVITO 250 E. 53RD STREET, APT 2902 80 P1NE STREET, SU1TE 300 NEW YORK, NY 10022 NEW YORK, NY 10005 LAW OFFICE OF JAMES J.TOOMEY PO BOX 2903 HARTFORD, CT 06104-2903 that being the address(s) within the state designated by the deponent for that purpose upon the preceding papers in this action, or the place where deponent then kept an office, between which places there then was and now is a regular communication by mail. Electroñic Service could not be effecMated as unrepresented party has no electronic means of service known to your affirmant. Deponent is over the age of eighteen (18) years. vtatt-/ MHL Ho y Our File No. 0445814114.1- Subscribed and sworn to before me this 2-r day of , 2021. Notary Public My Cceslssian Expires: 2p2L 4 of 4