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  • Mark Bussell, Anne Cronin v. Samson Moving, Ltd., Samson Storage, Inc. Other Matters - Contract - Other document preview
						
                                

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FILED: NEW YORK COUNTY CLERK 07/12/2019 11:27 PM INDEX NO. 155049/2018 NYSCEF DOC. NO. 3 RECEIVED NYSCEF: 07/12/2019 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF NEW YORK MARK BUSSELL and ANNE CRONIN, Index No. 155049/2018 Plaintiffs, -against- NOTICE OF MOTION SAMSON MOVING, LTD. and SAMSON STORAGE, INC. Defendants. PLEASE TAKE NOTICE, that upon the annexed affirmation of ELLERY IRELAND, of counsel to FISHMANLAW, PC, attorneys for Plaintiffs MARK BUSSELL and ANNE CRONIN, dated July 11, 2019, together with the exhibits annexed thereto and upon all prior papers and proceedings had herein, the undersigned shall move this Court, at 60 Centre Street, Room 130, New York, New York, 10013, at an IAS Part, on August 1, 2019 at 9:30 a.m., or as soon thereafter as counsel may be heard, for an Order: 1. Pursuant to CPLR § 3215(a), granting Plaintiffs a default judgment; 2. Pursuant to CPLR § 3215(b), directing a reference for the assessment of damages; and 2. Such other relief that this Court deems just and proper. Dated: July 12, 2019 New York, New York FISHM ÑLAW, PC By: El ry Ireland, of Counsel 305 Broadway, Suite 900 New York, NY 10007 (212) 897-5840 jfishman@fishmanlaw.nyc Attorneys for Plaintiffs 1 of 1