On May 11, 2018 a
Motion,Ex Parte
was filed
involving a dispute between
Stella Stolper,
and
Zarina Burbacki,
for Commercial Division
in the District Court of New York County.
Preview
FILED: NEW YORK COUNTY CLERK 01/17/2020 04:53 PM INDEX NO. 652352/2018
NYSCEF DOC. NO. 82 RECEIVED NYSCEF: 01/17/2020
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF NEW YORK
--------------------------------------------------------------------X
STELLA STOLPER,
NOTICE OF MOTION
Plaintiff,
Motion Sequence No. 7
-vs-
Index No. 652352/2018
ZARINA BURBACKI, Justice Assigned:
Defendant. Hon. Andrew S. Borrok, J.S.C.
--------------------------------------------------------------------X
PLEASE TAKE NOTICE that upon the Affirmation of Jonathan E. Neuman,
Esq., dated January 15, 2020, and the exhibits thereto, the accompanying Memorandum
of Law, and upon all of the pleadings and proceedings heretofore had herein, Defendant
will move this Court, at the courthouse located at 60 Centre Street, New York, New
York, in the Motion Submission Part Courtroom Room 130, on the 3rd day of March,
2020, at 9:30 o’clock in the forenoon of that day or as soon thereafter as counsel can be
heard, for an Order directing the following relief:
1) Pursuant to N.Y. C.P.L.R. §3211(a)(1), (a)(5), and (a)(7), dismissing
Plaintiff’s complaint in its entirety; and
2) Pursuant to 22 NYCRR 130-1.1, awarding attorney’s fees to Defendant for
Plaintiff’s frivolous conduct;
together with such other and further relief as this Court deems appropriate under the
circumstances.
The above entitled action is for conversion, breach of fiduciary duty, defamation,
accounting, and legal malpractice.
1 of 2
FILED: NEW YORK COUNTY CLERK 01/17/2020 04:53 PM INDEX NO. 652352/2018
NYSCEF DOC. NO. 82 RECEIVED NYSCEF: 01/17/2020
Pursuant to N.Y. C.P.L.R. 2214(b), answering papers, if any, are required to be
served upon the undersigned at least seven (7) days before the return date of this motion.
Dated: Fresh Meadows, New York
January 15, 2020
Respectfully submitted,
/Jonathan E. Neuman/
JONATHAN E. NEUMAN, ESQ.
Attorney for Defendant
176-25 Union Turnpike, Suite 230
Fresh Meadows, New York 11366
(347) 450-6710
(718) 228-3689 (fax)
jnesq@jenesqlaw.com
TO: Kruzhkov Russo PLLC
Attorneys for Plaintiff
350 Fifth Avenue, Suite 7230
New York, New York 10118
(212) 363-2000
(917) 591-7175 (fax)
marlen@kruzhkovrusso.com
2 of 2
Document Filed Date
January 17, 2020
Case Filing Date
May 11, 2018
Category
Commercial Division
For full print and download access, please subscribe at https://www.trellis.law/.
Preview
FILED: NEW YORK COUNTY CLERK 01/17/2020 04:53 PM INDEX NO. 652352/2018 NYSCEF DOC. NO. 82 RECEIVED NYSCEF: 01/17/2020 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF NEW YORK --------------------------------------------------------------------X STELLA STOLPER, NOTICE OF MOTION Plaintiff, Motion Sequence No. 7 -vs- Index No. 652352/2018 ZARINA BURBACKI, Justice Assigned: Defendant. Hon. Andrew S. Borrok, J.S.C. --------------------------------------------------------------------X PLEASE TAKE NOTICE that upon the Affirmation of Jonathan E. Neuman, Esq., dated January 15, 2020, and the exhibits thereto, the accompanying Memorandum of Law, and upon all of the pleadings and proceedings heretofore had herein, Defendant will move this Court, at the courthouse located at 60 Centre Street, New York, New York, in the Motion Submission Part Courtroom Room 130, on the 3rd day of March, 2020, at 9:30 o’clock in the forenoon of that day or as soon thereafter as counsel can be heard, for an Order directing the following relief: 1) Pursuant to N.Y. C.P.L.R. §3211(a)(1), (a)(5), and (a)(7), dismissing Plaintiff’s complaint in its entirety; and 2) Pursuant to 22 NYCRR 130-1.1, awarding attorney’s fees to Defendant for Plaintiff’s frivolous conduct; together with such other and further relief as this Court deems appropriate under the circumstances. The above entitled action is for conversion, breach of fiduciary duty, defamation, accounting, and legal malpractice. 1 of 2 FILED: NEW YORK COUNTY CLERK 01/17/2020 04:53 PM INDEX NO. 652352/2018 NYSCEF DOC. NO. 82 RECEIVED NYSCEF: 01/17/2020 Pursuant to N.Y. C.P.L.R. 2214(b), answering papers, if any, are required to be served upon the undersigned at least seven (7) days before the return date of this motion. Dated: Fresh Meadows, New York January 15, 2020 Respectfully submitted, /Jonathan E. Neuman/ JONATHAN E. NEUMAN, ESQ. Attorney for Defendant 176-25 Union Turnpike, Suite 230 Fresh Meadows, New York 11366 (347) 450-6710 (718) 228-3689 (fax) jnesq@jenesqlaw.com TO: Kruzhkov Russo PLLC Attorneys for Plaintiff 350 Fifth Avenue, Suite 7230 New York, New York 10118 (212) 363-2000 (917) 591-7175 (fax) marlen@kruzhkovrusso.com 2 of 2