On March 12, 2018 a
Motion,Ex Parte
was filed
involving a dispute between
Gb An Infant By His Mother And Natural Guardian Rayna Douglas,
Rayna Douglas,
and
Fast Lane Motors, Llc,
Jevan De Jani Simpson,
Kayde Palmer,
for Torts - Motor Vehicle
in the District Court of Queens County.
Preview
FILED: QUEENS COUNTY CLERK 07/07/2021 03:26 PM INDEX NO. 703719/2018
NYSCEF DOC. NO. 38 RECEIVED NYSCEF: 07/07/2021
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF QUEENS
____
INDEX NO. 703719/2018
G.B., an infant by his mother and natural guardian RAYNA
DOUGLAS and RAYNA DOUGLAS, Individual,
NOTICE OF MOTION
Plaintiffs,
-against-
JEVAN SIMPSON, KAYDE PALMER AND FAST LANE
MOTORS, LLC,
Defendants.
C O U N S E L O R S :
PLEASE TAKE NOTICE, that upon the annexed affidavit of Rayna E. Douglas, sworn
19*
to the day of April, 2019, the affirmation of Eric S. Cantor, dated the 7th day of July, 2021,
and upon all the pleadings and proceedings heretofore had herein, the undersigned will move
before this Court at the Courthouse located at Supreme Court, Queens County, 88-11 Sutphin
Büülev&rd, Jamaica, NY 11435, Part 19, Courtroom 44, in front of the Honorable Pam Jackman
16th 2021
Brown, on the day of August, at 9:30am in the forenoon of that day or as soon
thereafter as counsel can be heard:
For an order: (1) pursuant to CPLR 2004 extending Plaintiff's time to file for Default
Judgment, and (2) pursuant to Section 3215 of the Civil Practice Law and Rules directing the
entry of judgment upon default in favor of plaintiff and against all defeñdants on the issue of
liability and setting the matter down for an inquest as to damages, for an award of costs,
disbursements and reasonable attorney's fees to abide this motion, and for such other and further
relief as to this Court may seem just and proper.
1 of 2
FILED: QUEENS COUNTY CLERK 07/07/2021 03:26 PM INDEX NO. 703719/2018
NYSCEF DOC. NO. 38 RECEIVED NYSCEF: 07/07/2021
The above-entitled action is for personal injuries. This action is not on the trial calendar.
TAKE FURTHER NOTICE that, pursuant to Section 2214(b) of the Civil Practice Law
and Rules, all answering papers, if any, shall be served at least seven (7) days before the return
date of this motion.
Dated: Astoria, New York
July 7, 2021
By: Eric S. Cantor, Esq.
SACCO & FILLAS, LLP
Attorneys for Plaintiff
31-19 Newtown Avenue
Seventh Floor
Astoria, New York 11102
(718) 746-3440
Our File # 20009-17
TO:
DEFENDANTS (see affidavit of service)
2 of 2
Document Filed Date
July 07, 2021
Case Filing Date
March 12, 2018
Category
Torts - Motor Vehicle
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Preview
FILED: QUEENS COUNTY CLERK 07/07/2021 03:26 PM INDEX NO. 703719/2018 NYSCEF DOC. NO. 38 RECEIVED NYSCEF: 07/07/2021 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF QUEENS ____ INDEX NO. 703719/2018 G.B., an infant by his mother and natural guardian RAYNA DOUGLAS and RAYNA DOUGLAS, Individual, NOTICE OF MOTION Plaintiffs, -against- JEVAN SIMPSON, KAYDE PALMER AND FAST LANE MOTORS, LLC, Defendants. C O U N S E L O R S : PLEASE TAKE NOTICE, that upon the annexed affidavit of Rayna E. Douglas, sworn 19* to the day of April, 2019, the affirmation of Eric S. Cantor, dated the 7th day of July, 2021, and upon all the pleadings and proceedings heretofore had herein, the undersigned will move before this Court at the Courthouse located at Supreme Court, Queens County, 88-11 Sutphin Büülev&rd, Jamaica, NY 11435, Part 19, Courtroom 44, in front of the Honorable Pam Jackman 16th 2021 Brown, on the day of August, at 9:30am in the forenoon of that day or as soon thereafter as counsel can be heard: For an order: (1) pursuant to CPLR 2004 extending Plaintiff's time to file for Default Judgment, and (2) pursuant to Section 3215 of the Civil Practice Law and Rules directing the entry of judgment upon default in favor of plaintiff and against all defeñdants on the issue of liability and setting the matter down for an inquest as to damages, for an award of costs, disbursements and reasonable attorney's fees to abide this motion, and for such other and further relief as to this Court may seem just and proper. 1 of 2 FILED: QUEENS COUNTY CLERK 07/07/2021 03:26 PM INDEX NO. 703719/2018 NYSCEF DOC. NO. 38 RECEIVED NYSCEF: 07/07/2021 The above-entitled action is for personal injuries. This action is not on the trial calendar. TAKE FURTHER NOTICE that, pursuant to Section 2214(b) of the Civil Practice Law and Rules, all answering papers, if any, shall be served at least seven (7) days before the return date of this motion. Dated: Astoria, New York July 7, 2021 By: Eric S. Cantor, Esq. SACCO & FILLAS, LLP Attorneys for Plaintiff 31-19 Newtown Avenue Seventh Floor Astoria, New York 11102 (718) 746-3440 Our File # 20009-17 TO: DEFENDANTS (see affidavit of service) 2 of 2