Preview
FILED: RICHMOND COUNTY CLERK 08/18/2021 02:46 PM INDEX NO. 152064/2020
NYSCEF DOC. NO. 13 RECEIVED NYSCEF: 08/18/2021
FILE #: 32137
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF RICHMOND
KEESHA WOODS
Index No 152064/2020
Plaintiff(s),
-against. NOTICE OF MOTION
FOR DEFAULT
JUDGMENT
MUSLEH-FOREST REALTY, LLC, MEKKAH
MEDITERANEAN MARKET and DOLLAR GENERAL
STORE
Defendant(s).
PLEASE TAKE NOTICE, that upon the affirmatica of Stephen J Smith, duly affirmed on
August 17, 2021 the Affidavit of merit together with the exhibits annexed thereto, and
upon all the pleadings and proceedings heretofore had herein, the undersigned will
move this Court before the Hon Lizette Colon, 26 Central Avenue IAS Part 21, IAS21M,
Staten Island NY 10301 at on (Thursday ) September 23, 2021 at 9:30 A.M., or as
soon thereafter as counsel may he heard for an Order pursuant to CPLR 3215(a(b)
directing that a Default Judgment be entered against MEKKAH MEDITERANEAN
MARKET and DOLLAR GENERAL STORE. or in the alternative, setting this matter
down for an inquest in favor of the Plaintiff, assessing damages in a sum certain or for
attorneys'
a sum, which can by computation be made certain, awarding costs, fees and
sanctions to Plaintiff's attorneys, and for such other relief as this Court deems just and
proper
1 of 4
FILED: RICHMOND COUNTY CLERK 08/18/2021 02:46 PM INDEX NO. 152064/2020
NYSCEF DOC. NO. 13 RECEIVED NYSCEF: 08/18/2021
PLEASE TAKE FURTHER NOTICE, that answering affidavits , ifany are to be served
upon the undersigned within seven (7) days prior to the return date of the within
application.
Date August 17, 2021
s72p222 p. s1rT75. Esc
STEPHEN J. SMITH, ESQ.
E-Signature Pursuant to STL § 304(2)
Subin Associates
Attorneys for Plaintiff
22nd 23rd
150 Broadway, and FlOOr
New York, NY 10038
(212) 285-3800
TO:
Via Certified Mail Return Receipt Requested and Regular Mail
MEKKAH MEDITERANEAN MARKET
2256 Forest Avenue
Staten Island, New York 10303
Via Certified Mail Return Receipt Requested and Regular Mail
DOLLARGENERAL STORE
2264 Forest Avenue
Staten island, New York 10303
LAW OFFICE OF KEVIN J. PHILBIN
Attorneys for Defendant
MUSLEH-FOREST REALTY, LLC
13th
One Whitehall Street, FlOOr
New York, New York 10004-2109
Tel.: (212) 248-9100
LF Matter No.: 20-019377
2 of 4
FILED: RICHMOND COUNTY CLERK 08/18/2021 02:46 PM INDEX NO. 152064/2020
NYSCEF DOC. NO. 13 RECEIVED NYSCEF: 08/18/2021
CERTIFICATION
I hereby certify pursuant to 22 NYCRR §202.8-b that the foregoing brief was prepared on
a computer using Microsoft Word
A proportionally spaced typeface was used as follows:
Name of Type face: Ariel
Point Size: 12
Line Spacing: Double
Word Count: 3352 The total number of words in this brief, inclusive of point
headings and footnotes and exclusive of pages containing the table of contents, table of
authorities, and signature block is: 48
Dated: New York, New York
August 17 , 2021
Stephen J. Smith_
E-Signature Pursuant STL § 304(2)
STEPHEN J. SMITH, ESQ.
3 of 4
FILED: RICHMOND COUNTY CLERK 08/18/2021 02:46 PM INDEX NO. 152064/2020
NYSCEF DOC. NO. 13 RECEIVED NYSCEF: 08/18/2021
FILE #: 32137
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF RICHMOND
X
KEESHA WOODS
Index No 152064/2020
Plaintiff(s),
-against-
MUSLEH-FOREST REALTY, LLC, MEKKAH
MEDITERANEAN MARKET and DOLLAR GENERAL
STORE
Defendant(s).
... -X
NOTICE OF MOTION FOR DEFAULT JUDGMENT
SUBIN ASSOCIATES, LLP
Attorneys forPlaintiff
23RD
150 Broadway, FlOOr
New York, NY 10038
Telephone (212) 285-3800
(FAX)"
"WE DO NOT ACCEPT SERVICE BY ELECTRONIC TRANSMISSION
To: To: I hereby certify pursuant to 22 NYCRR § 130-1.1-a that, to the best of my knowledge,
information and belief, formed after an inquiry reasonable under the circumstances, the
presentation of the papers listed below or the contentions therein are not frivolous as defined in
22 NYCRR § 130-1.1(c)
Date August 17, 2021
STSPN27t p. S2eT77. E52.
STEPHEN J. SMITH, ESQ.
E-Signature Pursuant to STL § 304(2)
Service of a copy of the within is hereby admitted
Dated,
......................................................
Attorney(s) for SUBIN ASSOCIATES, LLP
Attorneys for Plaintiff
23RD
150 Broadway, FlOOr
New York, NY 10038
(212) 285-3800
4 of 4
Preview
FILED: RICHMOND COUNTY CLERK 08/18/2021 02:46 PM INDEX NO. 152064/2020 NYSCEF DOC. NO. 13 RECEIVED NYSCEF: 08/18/2021 FILE #: 32137 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF RICHMOND KEESHA WOODS Index No 152064/2020 Plaintiff(s), -against. NOTICE OF MOTION FOR DEFAULT JUDGMENT MUSLEH-FOREST REALTY, LLC, MEKKAH MEDITERANEAN MARKET and DOLLAR GENERAL STORE Defendant(s). PLEASE TAKE NOTICE, that upon the affirmatica of Stephen J Smith, duly affirmed on August 17, 2021 the Affidavit of merit together with the exhibits annexed thereto, and upon all the pleadings and proceedings heretofore had herein, the undersigned will move this Court before the Hon Lizette Colon, 26 Central Avenue IAS Part 21, IAS21M, Staten Island NY 10301 at on (Thursday ) September 23, 2021 at 9:30 A.M., or as soon thereafter as counsel may he heard for an Order pursuant to CPLR 3215(a(b) directing that a Default Judgment be entered against MEKKAH MEDITERANEAN MARKET and DOLLAR GENERAL STORE. or in the alternative, setting this matter down for an inquest in favor of the Plaintiff, assessing damages in a sum certain or for attorneys' a sum, which can by computation be made certain, awarding costs, fees and sanctions to Plaintiff's attorneys, and for such other relief as this Court deems just and proper 1 of 4 FILED: RICHMOND COUNTY CLERK 08/18/2021 02:46 PM INDEX NO. 152064/2020 NYSCEF DOC. NO. 13 RECEIVED NYSCEF: 08/18/2021 PLEASE TAKE FURTHER NOTICE, that answering affidavits , ifany are to be served upon the undersigned within seven (7) days prior to the return date of the within application. Date August 17, 2021 s72p222 p. s1rT75. Esc STEPHEN J. SMITH, ESQ. E-Signature Pursuant to STL § 304(2) Subin Associates Attorneys for Plaintiff 22nd 23rd 150 Broadway, and FlOOr New York, NY 10038 (212) 285-3800 TO: Via Certified Mail Return Receipt Requested and Regular Mail MEKKAH MEDITERANEAN MARKET 2256 Forest Avenue Staten Island, New York 10303 Via Certified Mail Return Receipt Requested and Regular Mail DOLLARGENERAL STORE 2264 Forest Avenue Staten island, New York 10303 LAW OFFICE OF KEVIN J. PHILBIN Attorneys for Defendant MUSLEH-FOREST REALTY, LLC 13th One Whitehall Street, FlOOr New York, New York 10004-2109 Tel.: (212) 248-9100 LF Matter No.: 20-019377 2 of 4 FILED: RICHMOND COUNTY CLERK 08/18/2021 02:46 PM INDEX NO. 152064/2020 NYSCEF DOC. NO. 13 RECEIVED NYSCEF: 08/18/2021 CERTIFICATION I hereby certify pursuant to 22 NYCRR §202.8-b that the foregoing brief was prepared on a computer using Microsoft Word A proportionally spaced typeface was used as follows: Name of Type face: Ariel Point Size: 12 Line Spacing: Double Word Count: 3352 The total number of words in this brief, inclusive of point headings and footnotes and exclusive of pages containing the table of contents, table of authorities, and signature block is: 48 Dated: New York, New York August 17 , 2021 Stephen J. Smith_ E-Signature Pursuant STL § 304(2) STEPHEN J. SMITH, ESQ. 3 of 4 FILED: RICHMOND COUNTY CLERK 08/18/2021 02:46 PM INDEX NO. 152064/2020 NYSCEF DOC. NO. 13 RECEIVED NYSCEF: 08/18/2021 FILE #: 32137 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF RICHMOND X KEESHA WOODS Index No 152064/2020 Plaintiff(s), -against- MUSLEH-FOREST REALTY, LLC, MEKKAH MEDITERANEAN MARKET and DOLLAR GENERAL STORE Defendant(s). ... -X NOTICE OF MOTION FOR DEFAULT JUDGMENT SUBIN ASSOCIATES, LLP Attorneys forPlaintiff 23RD 150 Broadway, FlOOr New York, NY 10038 Telephone (212) 285-3800 (FAX)" "WE DO NOT ACCEPT SERVICE BY ELECTRONIC TRANSMISSION To: To: I hereby certify pursuant to 22 NYCRR § 130-1.1-a that, to the best of my knowledge, information and belief, formed after an inquiry reasonable under the circumstances, the presentation of the papers listed below or the contentions therein are not frivolous as defined in 22 NYCRR § 130-1.1(c) Date August 17, 2021 STSPN27t p. S2eT77. E52. STEPHEN J. SMITH, ESQ. E-Signature Pursuant to STL § 304(2) Service of a copy of the within is hereby admitted Dated, ...................................................... Attorney(s) for SUBIN ASSOCIATES, LLP Attorneys for Plaintiff 23RD 150 Broadway, FlOOr New York, NY 10038 (212) 285-3800 4 of 4