FILED: NEW YORK COUNTY CLERK 10/12/ :48 PM INDEX NO /2013 NYSCEF DOC. NO. 271 RECEIVED NYSCEF: 10/12/2018

Size: px

Start display at page:

Download "FILED: NEW YORK COUNTY CLERK 10/12/ :48 PM INDEX NO /2013 NYSCEF DOC. NO. 271 RECEIVED NYSCEF: 10/12/2018"

Oscar Mills
5 years ago
Views:

1 Index No.: /2013 (ECF) v. ACTION CARTING ENVIRONMENTAL SERVICES, INC., BCRE GRAND STREET OWNER, LLC., BCRE GRAND HOTEL, LLC., BCRE GRAND RESTAURANT, LLC., BCRE GRAND CAFE, LLC., DHG NEW YORK HOTEL MANAGEMENT COMPANY, LLC, DENIHAN OWNERSHIP COMPANY, LLC, JAMES HOTEL MANAGEMENT COMPANY, LLC., NOTICE OF MOTION FOR SUMMARY JUDGMENT MOTION BY: DATE and TIME: PLACE: SUPPORTING PAPERS: Defendants, Denihan Ownership Company, LLC, DHG New York Hotel Management Company, LLC and James Hotel Management Company, LLC November 14, 2018 at 9:30 A.M.,, 60 Centre Street New York, New York before the presiding Justice of the Motion Submissions Part, Room 130 Affirmation of Richard C. Prezioso and Memorandum of Law with attachments thereto. RELIEF DEMANDED: (a) (b) (c) An order pursuant to CPLR 3212 granting Summary Judgment to defendant and dismissing the Complaint and any and all cross claims. An order pursuant to CPLR 3212(a), granting Defendant summary judgment on the issue of liability as for their cross-claim of contractual indemnification. Such other and further relief as this Court deems just and proper. 1 of 5

2 ANSWERING PAPERS: Service upon movant to be made at least seven (7) days prior to the return date of this motion. DATED: New York, New York October 12, 2018 Yours, etc., EUSTACE, MARQUEZ, EPSTEIN, PREZIOSO & YAPCHANYK Denihan Ownership Company, LLC, DHG New York Hotel Management Company, LLC and James Hotel Management Company, LLC Office and Post Office Address 55 Water Street, 28th Floor New York, New York (212) By: TO: Richard C. Prezioso Edelman, Krasin & Jaye, PLLC Attorneys for Plaintiff Youssouf Dembele a/k/a Malaha Salik 7001 Brush Hollow Road, Suite 100 Westbury, New York (516) The Law Offices of Leon R. Kowalski Attorneys for Defendant, Action Carting Environmental Services, Inc. 12 Metrotech Center, 28th Floor Brooklyn, New York (718) Strongin Rothman & Abrams, LLP BCRE Grand Street Owner, LLC, BCRE Grand Hotel, LLC. BCRE Grand Restaurant, LLC & BCRE Grand Cafe, LLC. 80 Pine Street, 10th Floor New York, New York (212) of 5

3 Index No.: /2013 (ECF) v. AFFIDAVIT OF SERVICE ACTION CARTING ENVIRONMENTAL SERVICES, INC., BCRE GRAND STREET OWNER, LLC., BCRE GRAND HOTEL, LLC., BCRE GRAND RESTAURANT, LLC., BCRE GRAND CAFE, LLC., DHG NEW YORK HOTEL MANAGEMENT COMPANY, LLC, DENIHAN OWNERSHIP COMPANY, LLC, JAMES HOTEL MANAGEMENT COMPANY, LLC., STATE OF NEW YORK ) ss. ) Naraida Yousuff, being duly sworn, deposes and says: 1. That I am over the age of eighteen years and not a party to this action. 2. That on October 12, 2018, I served upon: Edelman, Krasin & Jaye, PLLC Attorneys for Youssouf Dembele a/k/a Malaha Salik 7001 Brush Hollow Road, Suite 100 Westbury, New York (516) The Law Offices of Leon R. Kowalski Attorneys for Defendant, Action Carting Environmental Services, Inc. 12 Metrotech Center, 28th Floor Brooklyn, New York (718) of 5

4 Strongin Rothman & Abrams, LLP BCRE Grand Street Owner, LLC, BCRE Grand Hotel, LLC. BCRE Grand Restaurant, LLC & BCRE Grand Cafe, LLC. 80 Pine Street, 10th Floor New York, New York (212) a true copy of the annexed MOTION FOR SUMMARY JUDGMENT WITH AFFIRMATION IN SUPPORT AND MEMORANDUM OF LAW by depositing them endorsed in a postpaid properly addressed wrapper, in a post office or, official depository under the exclusive care and custody of the United States Postal Service within the State of New York, at the address designated by him or her upon the last paper served by him or her in the action and by electronically filing same. DATED: October 12, 2018 New York, New York Na aida Yousuff Sworn and subscribed before me on October 12, 2018 Notary J. ubhe. AA saradine tewis Notary Public, State of New York No. 01LE Qualified,in Kings County ' Commissidn Expires 07/27 Of 4 of 5

5 Index No.: /2013 (ECF) against ACTION CARTING ENVIRONMENTAL SERVICES, INC., BCRE GRAND STREET OWNER, LLC., BCRE GRAND HOTEL, LLC., BCRE GRAND RESTAURANT, LLC., BCRE GRAND CAFE, LLC., DHG NEW YORK HOTEL MANAGEMENT COMPANY, LLC, DENIHAN OWNERSHIP COMPANY, LLC, JAMES HOTEL MANAGEMENT COMPANY, LLC., MOTION FOR SUMMARY JUDGMENT WITH AFFIRMATION IN SUPPORT EUSTACE, MARQUEZ, EPSTEIN, PREZIOSO & YAPCHANYK Attorneys for Defendants Denihan Ownership Company, LLC, DHG New York Hotel Management Company, LLC and James Hotel Management Company, LLC Office and Post Office Address 55 Water Street, 28th Floor New York, New York (212) of 5

FILED: NEW YORK COUNTY CLERK 05/14/ :29 PM INDEX NO /2017 NYSCEF DOC. NO. 72 RECEIVED NYSCEF: 05/14/2018

FILED: NEW YORK COUNTY CLERK 05/14/ :29 PM INDEX NO /2017 NYSCEF DOC. NO. 72 RECEIVED NYSCEF: 05/14/2018 OUR FILE NO.: 950.170010 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF NEW YORK ------------------------------------------------------------------------x Index No.: i"~o.. 152517/2017 SUZANNE BOROWICZ,