On October 29, 2018 a
Motion,Ex Parte
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.
Preview
FILED: KINGS COUNTY CLERK 12/17/2018 03:36 PM INDEX NO. 521723/2018
NYSCEF DOC. NO. 8 RECEIVED NYSCEF: 12/17/2018
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF KINGS
------------------------------------ ____----------..
ABRAHAM VARGAS MEDELLIN and Index No.: 521723/2018
JOSE ALFONSO DELGADO PRIEGO,
Plaintiffs,
-against- NOTICE OF MOTION
HAPPY TRANSPORTATION SERVICE, LLC and
RAISER-NY, LLC,
Defendants,
--------------------------------------------------------
PLEASE TAKE NOTICE that upon the affirmation of Daniel A. Berger, Esq., dated
December 17, 2018, the exhibits annexed hereto, and upon all the pleadings and proceedings of this
action, plaintiffs ABRAHAM VARGAS MEDELLIN and JOSE ALFONSO DELGADO PRIEGO
will move this Court at an IAS Part, at the courthouse located at 360 Adams Street, Room 538,
Brooklyn, New York on January 10, 2019 at 10:15 o'clock in the forenoon of that day, or as soon
thereafter as counsel can be heard, for an Order:
(a) Granting summary judgment to plaintiffs as to liability, pursuant to CPLR §
3212;
plaintiffs'
(b) Setting this matter down for an immediate trial on the sole issue of
damages; and
(c) For such other relief as this Court may deem just and proper.
PLEASE TAKE FURTHER NOTICE that answering affidavits, if any, must be served no
later than seven days prior to the return date.
Dated: New York, New York
December 17, 2018
Yours,
JAROSLAWICZ & JAROS PLLC
Attorneys for Plaintiffs
1 of 2
FILED: KINGS COUNTY CLERK 12/17/2018 03:36 PM INDEX NO. 521723/2018
NYSCEF DOC. NO. 8 RECEIVED NYSCEF: 12/17/2018
By: aniel A. Berger
225 roadway, 24th or
Ne York, New York 10007
(212) 227-2780
To:
WILSON ELSER MOSKOWITZ EDELMAN & DICKER LLP
Attorneys for Defendant
RAISER-NY, LLC
1133 Westchester Avenue
White Plains, New York 10604
LAW OFFICES OF NANCY L. ISSERLIS
Attorneys for Defendant
HAPPY TRANSPORTATION SERVICE, LLC
43rd
36-01 Avenue
Long Island City, New York 11101
- 2 -
2 of 2
Document Filed Date
December 17, 2018
Case Filing Date
October 29, 2018
Category
Torts - Motor Vehicle
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FILED: KINGS COUNTY CLERK 12/17/2018 03:36 PM INDEX NO. 521723/2018 NYSCEF DOC. NO. 8 RECEIVED NYSCEF: 12/17/2018 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF KINGS ------------------------------------ ____----------.. ABRAHAM VARGAS MEDELLIN and Index No.: 521723/2018 JOSE ALFONSO DELGADO PRIEGO, Plaintiffs, -against- NOTICE OF MOTION HAPPY TRANSPORTATION SERVICE, LLC and RAISER-NY, LLC, Defendants, -------------------------------------------------------- PLEASE TAKE NOTICE that upon the affirmation of Daniel A. Berger, Esq., dated December 17, 2018, the exhibits annexed hereto, and upon all the pleadings and proceedings of this action, plaintiffs ABRAHAM VARGAS MEDELLIN and JOSE ALFONSO DELGADO PRIEGO will move this Court at an IAS Part, at the courthouse located at 360 Adams Street, Room 538, Brooklyn, New York on January 10, 2019 at 10:15 o'clock in the forenoon of that day, or as soon thereafter as counsel can be heard, for an Order: (a) Granting summary judgment to plaintiffs as to liability, pursuant to CPLR § 3212; plaintiffs' (b) Setting this matter down for an immediate trial on the sole issue of damages; and (c) For such other relief as this Court may deem just and proper. PLEASE TAKE FURTHER NOTICE that answering affidavits, if any, must be served no later than seven days prior to the return date. Dated: New York, New York December 17, 2018 Yours, JAROSLAWICZ & JAROS PLLC Attorneys for Plaintiffs 1 of 2 FILED: KINGS COUNTY CLERK 12/17/2018 03:36 PM INDEX NO. 521723/2018 NYSCEF DOC. NO. 8 RECEIVED NYSCEF: 12/17/2018 By: aniel A. Berger 225 roadway, 24th or Ne York, New York 10007 (212) 227-2780 To: WILSON ELSER MOSKOWITZ EDELMAN & DICKER LLP Attorneys for Defendant RAISER-NY, LLC 1133 Westchester Avenue White Plains, New York 10604 LAW OFFICES OF NANCY L. ISSERLIS Attorneys for Defendant HAPPY TRANSPORTATION SERVICE, LLC 43rd 36-01 Avenue Long Island City, New York 11101 - 2 - 2 of 2