Preview
FILED: KINGS COUNTY CLERK 09/23/2021 02:34 PM INDEX NO. 510433/2019
NYSCEF DOC. NO. 39 RECEIVED NYSCEF: 09/23/2021
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF KINGS
------------------------------------X Index No.: 510433/2019
NICHOLAS GRANT,
Plaintiff(s),
-against- REPLY TO CROSS CLAIMS
147-02/12 LIBERTY AVE, LLC, JOUVAY NY, INC.
d/b/a JOUVAY NIGHT CLUB, ISAAC J. RIOS,
and PROFESSIONAL CORPORATE SECURITY
SEVICES, INC.,
Defendant(s).
------------ -----X
The defendants, JOUVAY NY, INC. d/b/a JOUVAY NIGHT CLUB, by their attorneys,
BONGIORNO, MONTIGLIO, MITCHELL & PALMIERI, PLLC, as and for their reply to
defendant, PROFESSIONAL CORPORATE SECURITY SERVICES, INC.'s cross-claim, alleges
upon information and belief:
AS AND FOR AN ANSWER TO A FIRST CROSS-CLAIM
"17"
FIRST: Denies each and every allegation contained in paragraphs designated of
the cross claim.
AS AND FOR AN ANSWER TO A SECOND CROSS-CLAIM
"18"
SECOND: Denies each and every allegation contained in paragraphs designated of
the cross claim.
AS AND FOR AN ANSWER TO A THIRD CROSS-CLAIM
"19"
THIRD: Denies each and allegation contained in paragraphs designated of
every
the cross claim.
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FILED: KINGS COUNTY CLERK 09/23/2021 02:34 PM INDEX NO. 510433/2019
NYSCEF DOC. NO. 39 RECEIVED NYSCEF: 09/23/2021
AS AND FOR AN ANSWER TO A FOURTH CROSS-CLAIM
"20"
FOURTH: Denies each and every allegation contained in paragraphs designated of
the cross claim.
WHEREFORE, defendants, JOUVAY NY, INC. d/b/a JOUVAY NIGHT CLUB, demands
judgment dismissing the cross claim of the defendant, PROFESSIONAL CORPORATE
SECURITY SERVICES, INC., together with the costs and disbursements of this action.
Dated: August 30, 2021
Mineola, New York -Ê
Yours, etc.
BONGIORNO, ÓN LIO;pIITCHELL
& PAL L .
By: Neil J. Palmieri, Esq.
Attorneys for JOUVAY NY INC. d/b/a
JOUVAY NIGHT CLUB
200 Old Country Road, Suite 680
Mineola, New York 11501
(516) 620-4490
Our File No.: FRS 016421 NJP
To: Law Offices of Bryan Barenbaum
Attorneys for Plaintiff
2060 Eastern Parkway
Brooklyn, New York 11207
(718) 421-1111
Black Marjieh & Sanford, LLP
Attorneys for 147-02/12 Liberty Ave., LLC
100 Clearbrook Road
Elmsford, New York 10523
(914) 704-4400
Goetz Schenker Blee & Wiederhorn
Attorneys for Professional Corporate Security Services, Inc.
2001
101 Greenwich Street, Floor
New York, New York 10006
(212) 363-6900
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FILED: KINGS COUNTY CLERK 09/23/2021 02:34 PM INDEX NO. 510433/2019
NYSCEF DOC. NO. 39 RECEIVED NYSCEF: 09/23/2021
AFFIDAVIT OF SERVICE BY ELECTRONIC FILING
STATE OF NEW YORK )
s.s.: )
COUNTY OF SUFFOLK )
TRACEY S. DAVIDA-HERBST, hereby swears the following to be true: that deponent is
not a party to this action, that she is of 18 years of age; and that she is employed by the office of
BONGIORNO, MONTIGLIO, MITCHELL & PALMIERI, PLLC, attorneys for defendant
JOUVAY NY, INC. d/b/a JOUVAY NIGHT CLUB, in the within matter; that the office address
is of said attorneys is 200 Old Country Road, Suite 680, Mineola, New York 11501, that on
September 23, 2021, deponent served upon
ALL PARTIES APPEARING ON THE NYSCEF WEBSITE AT THE EMAIL ADDRESSES
DESIGNATED BY SAID PARTIES.
A copy of itsReply to Cross Claim
T . DAVIDA-HE S
Sworn to before me this
23th
day Of September, 2021.
ALEX M. CARTER
Notary Public, State of New York
Registration #02CA6318681
in Nassau County
Qualified
Commission Expires Feb. 2, 2023
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FILED: KINGS COUNTY CLERK 09/23/2021 02:34 PM INDEX NO. 510433/2019
NYSCEF DOC. NO. 39 RECEIVED NYSCEF: 09/23/2021
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF KINGS INDEX NO. 510433/2019
NICHOLAS GRANT,
Plaintiff,
-against-
147-02/12 LTRERTY AVE, LLC, JOUVAY NY, INC. d/b/a JOUVAY NIGHT CLUB, ISAAC
J. RIOS, and PROFESSIONAL CORPORATE SECURITY SERVICES, INC.,
Defendants.
REPLY TO CROSS CLAIM
BONGIORNO
MONTIGLIO,
MITCHELL &
PALMlERI, PLLC
Attorneys for Jouvay NY Inc. d/b/a Jouvay Night Club
200 Old Country Road, Suite 680
Mineola, New York 11501
(516) 620-4490
File No.: FRS 016421 NJP
To:
Attorney(s) for
Service of a copy of the within is hereby admitted.
Dated: Attorneys for
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Preview
FILED: KINGS COUNTY CLERK 09/23/2021 02:34 PM INDEX NO. 510433/2019 NYSCEF DOC. NO. 39 RECEIVED NYSCEF: 09/23/2021 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF KINGS ------------------------------------X Index No.: 510433/2019 NICHOLAS GRANT, Plaintiff(s), -against- REPLY TO CROSS CLAIMS 147-02/12 LIBERTY AVE, LLC, JOUVAY NY, INC. d/b/a JOUVAY NIGHT CLUB, ISAAC J. RIOS, and PROFESSIONAL CORPORATE SECURITY SEVICES, INC., Defendant(s). ------------ -----X The defendants, JOUVAY NY, INC. d/b/a JOUVAY NIGHT CLUB, by their attorneys, BONGIORNO, MONTIGLIO, MITCHELL & PALMIERI, PLLC, as and for their reply to defendant, PROFESSIONAL CORPORATE SECURITY SERVICES, INC.'s cross-claim, alleges upon information and belief: AS AND FOR AN ANSWER TO A FIRST CROSS-CLAIM "17" FIRST: Denies each and every allegation contained in paragraphs designated of the cross claim. AS AND FOR AN ANSWER TO A SECOND CROSS-CLAIM "18" SECOND: Denies each and every allegation contained in paragraphs designated of the cross claim. AS AND FOR AN ANSWER TO A THIRD CROSS-CLAIM "19" THIRD: Denies each and allegation contained in paragraphs designated of every the cross claim. 1 of 4 FILED: KINGS COUNTY CLERK 09/23/2021 02:34 PM INDEX NO. 510433/2019 NYSCEF DOC. NO. 39 RECEIVED NYSCEF: 09/23/2021 AS AND FOR AN ANSWER TO A FOURTH CROSS-CLAIM "20" FOURTH: Denies each and every allegation contained in paragraphs designated of the cross claim. WHEREFORE, defendants, JOUVAY NY, INC. d/b/a JOUVAY NIGHT CLUB, demands judgment dismissing the cross claim of the defendant, PROFESSIONAL CORPORATE SECURITY SERVICES, INC., together with the costs and disbursements of this action. Dated: August 30, 2021 Mineola, New York -Ê Yours, etc. BONGIORNO, ÓN LIO;pIITCHELL & PAL L . By: Neil J. Palmieri, Esq. Attorneys for JOUVAY NY INC. d/b/a JOUVAY NIGHT CLUB 200 Old Country Road, Suite 680 Mineola, New York 11501 (516) 620-4490 Our File No.: FRS 016421 NJP To: Law Offices of Bryan Barenbaum Attorneys for Plaintiff 2060 Eastern Parkway Brooklyn, New York 11207 (718) 421-1111 Black Marjieh & Sanford, LLP Attorneys for 147-02/12 Liberty Ave., LLC 100 Clearbrook Road Elmsford, New York 10523 (914) 704-4400 Goetz Schenker Blee & Wiederhorn Attorneys for Professional Corporate Security Services, Inc. 2001 101 Greenwich Street, Floor New York, New York 10006 (212) 363-6900 2 of 4 FILED: KINGS COUNTY CLERK 09/23/2021 02:34 PM INDEX NO. 510433/2019 NYSCEF DOC. NO. 39 RECEIVED NYSCEF: 09/23/2021 AFFIDAVIT OF SERVICE BY ELECTRONIC FILING STATE OF NEW YORK ) s.s.: ) COUNTY OF SUFFOLK ) TRACEY S. DAVIDA-HERBST, hereby swears the following to be true: that deponent is not a party to this action, that she is of 18 years of age; and that she is employed by the office of BONGIORNO, MONTIGLIO, MITCHELL & PALMIERI, PLLC, attorneys for defendant JOUVAY NY, INC. d/b/a JOUVAY NIGHT CLUB, in the within matter; that the office address is of said attorneys is 200 Old Country Road, Suite 680, Mineola, New York 11501, that on September 23, 2021, deponent served upon ALL PARTIES APPEARING ON THE NYSCEF WEBSITE AT THE EMAIL ADDRESSES DESIGNATED BY SAID PARTIES. A copy of itsReply to Cross Claim T . DAVIDA-HE S Sworn to before me this 23th day Of September, 2021. ALEX M. CARTER Notary Public, State of New York Registration #02CA6318681 in Nassau County Qualified Commission Expires Feb. 2, 2023 3 of 4 FILED: KINGS COUNTY CLERK 09/23/2021 02:34 PM INDEX NO. 510433/2019 NYSCEF DOC. NO. 39 RECEIVED NYSCEF: 09/23/2021 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF KINGS INDEX NO. 510433/2019 NICHOLAS GRANT, Plaintiff, -against- 147-02/12 LTRERTY AVE, LLC, JOUVAY NY, INC. d/b/a JOUVAY NIGHT CLUB, ISAAC J. RIOS, and PROFESSIONAL CORPORATE SECURITY SERVICES, INC., Defendants. REPLY TO CROSS CLAIM BONGIORNO MONTIGLIO, MITCHELL & PALMlERI, PLLC Attorneys for Jouvay NY Inc. d/b/a Jouvay Night Club 200 Old Country Road, Suite 680 Mineola, New York 11501 (516) 620-4490 File No.: FRS 016421 NJP To: Attorney(s) for Service of a copy of the within is hereby admitted. Dated: Attorneys for 4 of 4