On October 29, 2018 a
Motion-Secondary
was filed
involving a dispute between
Abraham Vargas Medellin,
Jose Alfonso Delgado Priego,
and
Happy Transportation Service, Llc,
Rasier-Ny, Llc,
for Torts - Motor Vehicle
in the District Court of Kings County.
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At an IAS Part of the Supreme Court of the
State ofNew York, County of Kings,
held at the Kings County Supreme
Courthouse, 360 Adams Street, Brooklyn,
NY, on the day of , 2020.
PRESENT:
, J.S.C.
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF KINGS
--------- - - ----- --------- ---------- x Index No.: 521723/2018
ABRAHAM VARGAS MEDELLIN and
JOSE ALFONSO DELGADO PRIEGO,
Plaintiff, PROPOSED ORDER TO
SHOW CAUSE
-against-
HAPPY TRANSPORTATION SERVICE, LLC,
And RASIER-NY, LLC,
Defendants.
--------------------------------------------------------------------- x
HAPPY TRANSPORTATION, LLC,
Third-Party
Third-Party Plaintiff, Index No.:
-against-
11th
ST. WORKSHOP INC. and ADAM LONGORIA,
Third-Party Defendants.
---------------------------------------------------------------x
UPON the reading and filing of the annexed Affirmation of MATTHEW H. HERLIHY,
dated , 2020, in support of this application by RASIER-NY, LLC,
And upon all the papers and proceedings heretofore had herein, and sufficient cause
8098447v.1
appearing therefore, itis,
ORDERED, that the all discovery be hereby STAYED in the action commcaced on
behalf of plaintiffs ABRAHAM VARGAS MEDELLIN and JOSE ALFONSO DELGADO
11™
PRIEGO, pending the appearance of newly interplcad third-party defendants ST.
WORKSHOP INC. and ADAM LONGORIA, and until such a time that said third-party
defendants are able to conduct all discovery in the aforementioned third-party action to
reach that which has already been conducted in the origiiial action, thereby avoiding any
potentially unnecessary or duplicative discovery.
ORDERED, that all discovery in this matter be STAYED pending the deteriziiriation
of the subject application.
WHY an ORDER should not be made granting the request of defendant RASIER-NY,
LLC, for an immediate STAY of the all discovery in the action commenced by plaintiffs
ABRAHAM VARGAS MEDELLIN and JOSE ALFONSO DELGADO PRIEGO, until such a
time as set forth above.
And for such other and further relief as the Court may deem just and proper.
No prior application for such relief has been previously made.
ORDERED, that sufficient cause appearing thereon let service via electronic filing
(NYSCEF) OR first-class oversiiglit mail of a copy of this ORDER and the papers upon which
it isgranted, be made upon:
JAROSLAWICZ & JAROS PLLC
Attorneys for Plaintiffs
Abraham Vargas Medellin and
Jose Alfonso Delgado Priego
24th
225 Broadway, Floor
New York, New York 10007
(212) 227-2780
8098447v.1
LAW OFFICES OF NANCY L. ISSERLIS
Attorneys for Defendant/Third-Party Plaintiff
Happy Transportation Service, LLC
43rd
36-01 Avenue
Long Island City, New York 11101
(718) 361-1514
11d'
STREET WORKSHOP INC.
351 Manhattan Avenue
Jersey City, New Jersey 07307
ADAM LONGORIA
351 Manhattan Avenue
Jersey City, New Jersey 07307
On or
notice
before
of this
the _ day
application.
of 2020, be deemed good and sufficient service and
ENTER:
J.S.C.
8098447v.1
Document Filed Date
January 13, 2020
Case Filing Date
October 29, 2018
Category
Torts - Motor Vehicle
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At an IAS Part of the Supreme Court of the State ofNew York, County of Kings, held at the Kings County Supreme Courthouse, 360 Adams Street, Brooklyn, NY, on the day of , 2020. PRESENT: , J.S.C. SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF KINGS --------- - - ----- --------- ---------- x Index No.: 521723/2018 ABRAHAM VARGAS MEDELLIN and JOSE ALFONSO DELGADO PRIEGO, Plaintiff, PROPOSED ORDER TO SHOW CAUSE -against- HAPPY TRANSPORTATION SERVICE, LLC, And RASIER-NY, LLC, Defendants. --------------------------------------------------------------------- x HAPPY TRANSPORTATION, LLC, Third-Party Third-Party Plaintiff, Index No.: -against- 11th ST. WORKSHOP INC. and ADAM LONGORIA, Third-Party Defendants. ---------------------------------------------------------------x UPON the reading and filing of the annexed Affirmation of MATTHEW H. HERLIHY, dated , 2020, in support of this application by RASIER-NY, LLC, And upon all the papers and proceedings heretofore had herein, and sufficient cause 8098447v.1 appearing therefore, itis, ORDERED, that the all discovery be hereby STAYED in the action commcaced on behalf of plaintiffs ABRAHAM VARGAS MEDELLIN and JOSE ALFONSO DELGADO 11™ PRIEGO, pending the appearance of newly interplcad third-party defendants ST. WORKSHOP INC. and ADAM LONGORIA, and until such a time that said third-party defendants are able to conduct all discovery in the aforementioned third-party action to reach that which has already been conducted in the origiiial action, thereby avoiding any potentially unnecessary or duplicative discovery. ORDERED, that all discovery in this matter be STAYED pending the deteriziiriation of the subject application. WHY an ORDER should not be made granting the request of defendant RASIER-NY, LLC, for an immediate STAY of the all discovery in the action commenced by plaintiffs ABRAHAM VARGAS MEDELLIN and JOSE ALFONSO DELGADO PRIEGO, until such a time as set forth above. And for such other and further relief as the Court may deem just and proper. No prior application for such relief has been previously made. ORDERED, that sufficient cause appearing thereon let service via electronic filing (NYSCEF) OR first-class oversiiglit mail of a copy of this ORDER and the papers upon which it isgranted, be made upon: JAROSLAWICZ & JAROS PLLC Attorneys for Plaintiffs Abraham Vargas Medellin and Jose Alfonso Delgado Priego 24th 225 Broadway, Floor New York, New York 10007 (212) 227-2780 8098447v.1 LAW OFFICES OF NANCY L. ISSERLIS Attorneys for Defendant/Third-Party Plaintiff Happy Transportation Service, LLC 43rd 36-01 Avenue Long Island City, New York 11101 (718) 361-1514 11d' STREET WORKSHOP INC. 351 Manhattan Avenue Jersey City, New Jersey 07307 ADAM LONGORIA 351 Manhattan Avenue Jersey City, New Jersey 07307 On or notice before of this the _ day application. of 2020, be deemed good and sufficient service and ENTER: J.S.C. 8098447v.1