PRESENT: HON. JOAN KENNEY, J.S.C X BPC ASSOCIATES, LP, Index No.

Similar documents
: : : : : : : : : : : : I, Rafael Vergara, Esq., hereby affirm as follows pursuant to CPLR 2106:

At Part of the Supreme Court of the. of New York, at the Courthouse thereof, 60 PLAINTIFF, DEFENDANTS.

Sirs: Let the plaintiff, ELRAC LLC d/b/a ENTERPRISE RENT-A- PRESENT: Hon. GERALD LEBOVITS, J.S.C.

Counterclaim-Plaintiffs, Counterclaim-Defendants. IT IS HEREBY STIPULATED AND AGREED, by and between the undersigned

FILED: KINGS COUNTY CLERK 02/23/ :39 PM INDEX NO /2016 NYSCEF DOC. NO. 64 RECEIVED NYSCEF: 02/23/2018

FILED: NEW YORK COUNTY CLERK 01/20/2010 INDEX NO /2010

X

SETTLEMENT OF ORDER. PLEASE TAKE NOTICE that the annexed proposed order will be presented to Justice

Sample STATE OF NEW YORK CREDITOR. ,, SUMMONS Plaintiff, Index No. -vs- Date Filed: DEBTOR d/b/a. ,, Defendant. TO THE ABOVE-NAMED DEFENDANT:

Plaintiff, Justice Lynn R. Kotler IA Part 8 NOTICE OF SETTLEMENT. By:. Mitchell J. Ge r, Esq. 31 West 52nd Street. New York, New York 10019

FILED: NEW YORK COUNTY CLERK 02/14/ :34 AM INDEX NO /2016 NYSCEF DOC. NO. 28 RECEIVED NYSCEF: 02/14/2018

FILED: NEW YORK COUNTY CLERK 07/06/ :19 PM INDEX NO /2017 NYSCEF DOC. NO. 73 RECEIVED NYSCEF: 07/06/2017

FILED: NEW YORK COUNTY CLERK 08/27/ :37 PM INDEX NO /2014 NYSCEF DOC. NO. 67 RECEIVED NYSCEF: 08/27/2015. Exhibit

FILED: NEW YORK COUNTY CLERK 05/22/ :59 PM INDEX NO /2013 NYSCEF DOC. NO. 201 RECEIVED NYSCEF: 06/01/2015

- against - NOTICE OF MOTION

PLEASE TAKE NOTICE, that upon the annexed affirmation of JEENA R. BELIL, dated XXXXXXX 4,

Upon reading and filing the affirmation of Lawrence E. Tofel, sworn to on the 5th

FILED: NEW YORK COUNTY CLERK 09/03/ :13 PM

FILED: KINGS COUNTY CLERK 07/05/ :46 AM INDEX NO /2016 NYSCEF DOC. NO. 8 RECEIVED NYSCEF: 07/05/2017

FILED: ALBANY COUNTY CLERK 02/15/ :30 PM INDEX NO. A01268/2014 NYSCEF DOC. NO. 29 RECEIVED NYSCEF: 02/16/2017

FILED: NEW YORK COUNTY CLERK 03/19/ :45 PM INDEX NO /2016 NYSCEF DOC. NO. 168 RECEIVED NYSCEF: 03/19/2018

FILED: NEW YORK COUNTY CLERK 01/12/ :18 PM INDEX NO /2016 NYSCEF DOC. NO. 21 RECEIVED NYSCEF: 01/12/2018

FILED: NEW YORK COUNTY CLERK 04/15/ :21 PM INDEX NO /2014 NYSCEF DOC. NO. 23 RECEIVED NYSCEF: 04/15/2016

UPON READING AND FILING of the accompanying Affidavit of Charyn Powers,

FILED: NEW YORK COUNTY CLERK 06/14/ :52 AM INDEX NO /2016 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 06/14/2016

FILED: QUEENS COUNTY CLERK 08/14/ :01 PM INDEX NO /2017 NYSCEF DOC. NO. 125 RECEIVED NYSCEF: 08/14/2018

FILED: NEW YORK COUNTY CLERK 10/09/ :53 PM

Plaintiff, ...

FILED: NEW YORK COUNTY CLERK 03/08/ :28 PM

FILED: KINGS COUNTY CLERK 08/02/ :23 AM INDEX NO /2016 NYSCEF DOC. NO. 7 RECEIVED NYSCEF: 08/02/2016

Spallone v Spallone 2014 NY Slip Op 32412(U) September 11, 2014 Sup Ct, NY County Docket Number: /2013 Judge: Eileen A. Rakower Cases posted

FILED: NEW YORK COUNTY CLERK 08/21/ :59 AM INDEX NO /2017 NYSCEF DOC. NO. 6 RECEIVED NYSCEF: 08/22/2017

FILED: NEW YORK COUNTY CLERK 10/12/ :47 PM INDEX NO /2016 NYSCEF DOC. NO. 110 RECEIVED NYSCEF: 10/19/2018

Case 1:17-cv LAP Document 1 Filed 01/30/17 Page 1 of 3

FILED: NEW YORK COUNTY CLERK 08/11/ :17 PM INDEX NO /2016 NYSCEF DOC. NO. 85 RECEIVED NYSCEF: 08/11/2017

FILED: NEW YORK COUNTY CLERK 07/18/ :49 PM INDEX NO /2016 NYSCEF DOC. NO. 42 RECEIVED NYSCEF: 07/18/2018

FILED: NEW YORK COUNTY CLERK 08/01/ :41 PM INDEX NO /2015 NYSCEF DOC. NO. 31 RECEIVED NYSCEF: 08/01/2016. Exhibit C

FILED: NEW YORK COUNTY CLERK 12/14/ :34 PM INDEX NO /2016 NYSCEF DOC. NO. 10 RECEIVED NYSCEF: 12/14/2016

FILED: NEW YORK COUNTY CLERK 08/15/ :29 PM INDEX NO /2016 NYSCEF DOC. NO. 150 RECEIVED NYSCEF: 08/15/2016

FILED: KINGS COUNTY CLERK 09/11/ :43 PM INDEX NO /2017 NYSCEF DOC. NO. 47 RECEIVED NYSCEF: 09/11/2017

FILED: NEW YORK COUNTY CLERK 07/27/ :37 PM INDEX NO /2015 NYSCEF DOC. NO. 66 RECEIVED NYSCEF: 07/27/2018

FILED: NEW YORK COUNTY CLERK 07/26/2013 INDEX NO /2013 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 07/26/2013

FILED: NEW YORK COUNTY CLERK 03/08/ :56 PM INDEX NO /2017 NYSCEF DOC. NO. 50 RECEIVED NYSCEF: 03/08/2018

AFFIDAVIT OF DAVID A. SCHEFFEL IN SUPPORT OF MOTION FOR ADMISSIONS OF THOMAS P. SWIGERT AND ERIN E. CONTI PRO HAC VICE

be heard, why an order should not be made and entered herein:

FILED: NEW YORK COUNTY CLERK 07/06/ :22 PM INDEX NO /2017 NYSCEF DOC. NO. 52 RECEIVED NYSCEF: 07/06/2018

FILED: KINGS COUNTY CLERK 09/13/ :13 PM INDEX NO /2017 NYSCEF DOC. NO. 49 RECEIVED NYSCEF: 09/13/2017

FILED: NEW YORK COUNTY CLERK 04/06/ :25 AM INDEX NO /2016 NYSCEF DOC. NO. 59 RECEIVED NYSCEF: 04/06/2018

FILED: NEW YORK COUNTY CLERK 01/05/ :46 PM INDEX NO /2015 NYSCEF DOC. NO. 57 RECEIVED NYSCEF: 01/05/2018

FILED: NASSAU COUNTY CLERK 07/31/ :44 PM INDEX NO /2015 NYSCEF DOC. NO. 10 RECEIVED NYSCEF: 07/31/2015

FILED: BRONX COUNTY CLERK 06/04/ :20 AM INDEX NO /2017E NYSCEF DOC. NO. 59 RECEIVED NYSCEF: 06/04/2018

FILED: NEW YORK COUNTY CLERK 02/07/ :51 PM

Case reg Doc 82 Filed 03/24/15 Entered 03/24/15 18:04:39

herein, counsel will move this Court before the Honorable Denny Chin, United States District

Case reg Doc 46 Filed 03/19/15 Entered 03/19/15 13:57:13

FILED: NEW YORK COUNTY CLERK 01/12/ :05 PM INDEX NO /2016 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 01/12/2016

Plaintiff, -against- NOTICE OF MOTION

CLASSINA OSBORNE, -against- SUMMONS Plaintiff resides at TO THE ABOVE-NAMED DEFENDANT:

FILED: NEW YORK COUNTY CLERK 10/25/ :56 PM INDEX NO /2016 NYSCEF DOC. NO. 24 RECEIVED NYSCEF: 10/25/2016

Defendants. UPON review of the Notice of Motion dated June 10, 2016, the attorney Affirmation

FILED: NEW YORK COUNTY CLERK 01/02/ :16 PM INDEX NO /2017 NYSCEF DOC. NO. 32 RECEIVED NYSCEF: 01/02/2018

Defendant, -and- ANTONIA SHAPOLSKY, SABRINA SHAPOLSKY, CHANTAL MEYERS, and JOHN DOES 1-100, Relief Defendants.

FILED: NEW YORK COUNTY CLERK 03/21/ :36 PM INDEX NO /2013 NYSCEF DOC. NO. 65 RECEIVED NYSCEF: 03/21/2016 EXHIBIT A

FILED: SUFFOLK COUNTY CLERK 10/13/ :12 PM INDEX NO /2017 NYSCEF DOC. NO. 13 RECEIVED NYSCEF: 10/13/2017

FILED: NEW YORK COUNTY CLERK 04/24/ :42 PM INDEX NO /2016 NYSCEF DOC. NO. 61 RECEIVED NYSCEF: 04/24/2018

FILED: NEW YORK COUNTY CLERK 05/31/ :50 PM INDEX NO /2015 NYSCEF DOC. NO. 52 RECEIVED NYSCEF: 06/07/2016

FILED: NEW YORK COUNTY CLERK 09/16/ :12 PM INDEX NO /2014 NYSCEF DOC. NO. 21 RECEIVED NYSCEF: 09/16/2015

FILED: NASSAU COUNTY CLERK 02/13/ :24 PM INDEX NO /2016 NYSCEF DOC. NO. 14 RECEIVED NYSCEF: 02/13/2017

FILED: NEW YORK COUNTY CLERK 07/11/ :31 PM INDEX NO /2017 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 07/11/2017

FILED: NEW YORK COUNTY CLERK 03/21/ :34 PM INDEX NO /2017 NYSCEF DOC. NO. 36 RECEIVED NYSCEF: 03/21/2017

FILED: NEW YORK COUNTY CLERK 02/13/ :25 PM INDEX NO /2012 NYSCEF DOC. NO. 155 RECEIVED NYSCEF: 02/13/2017

FILED: NEW YORK COUNTY CLERK 07/26/ :03 PM INDEX NO /2016 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 07/26/2016

YOU ARE HEREBY SUMMONED to answer the Complaint in this action and to serve a

FILED: KINGS COUNTY CLERK 06/13/ :17 PM INDEX NO /2013 NYSCEF DOC. NO. 57 RECEIVED NYSCEF: 06/13/2018

FILED: NEW YORK COUNTY CLERK 10/03/ :34 AM INDEX NO /2014 NYSCEF DOC. NO. 34 RECEIVED NYSCEF: 10/03/2014

Upon reading and filing the annexed affidavit of plaintiff,

FILED: QUEENS COUNTY CLERK 10/02/ :40 PM INDEX NO /2016 NYSCEF DOC. NO. 16 RECEIVED NYSCEF: 10/02/2016

FILED: NEW YORK COUNTY CLERK 08/22/ :01 AM INDEX NO /2017 NYSCEF DOC. NO. 25 RECEIVED NYSCEF: 08/22/2017

FILED: NEW YORK COUNTY CLERK 12/28/ :04 PM INDEX NO /2013 NYSCEF DOC. NO. 19 RECEIVED NYSCEF: 12/28/2016

Upon reading and filing the sworn narrative of Dr. Inna Khval, sworn to July 25, 2018;

FILED: NEW YORK COUNTY CLERK 04/18/ :19 PM INDEX NO /2016 NYSCEF DOC. NO. 314 RECEIVED NYSCEF: 04/18/2018

Baker, Leshko, Saline & Drapeau, LLP, answering the complaint of the plaintiff,

FILED: NEW YORK COUNTY CLERK 08/11/ :47 PM INDEX NO /2016 NYSCEF DOC. NO. 3 RECEIVED NYSCEF: 08/11/2016

(718) Jordan Greenberger, Esq. Ouzounian v. Herrera et al.; No /2017 Scheduling Sanctions Motion (Motion Sequence 006)

HOROWITZ LAW GROUP PLLC

your failure to answer, Judgment will be taken against you by default for the relief demanded in the Complaint.

FILED: NEW YORK COUNTY CLERK 03/15/ :05 PM INDEX NO /2015 NYSCEF DOC. NO. 54 RECEIVED NYSCEF: 03/15/2017

FILED: NEW YORK COUNTY CLERK 02/01/ :52 PM INDEX NO /2016 NYSCEF DOC. NO. 50 RECEIVED NYSCEF: 02/01/2017

FILED: KINGS COUNTY CLERK 01/02/ :17 PM INDEX NO /2016 NYSCEF DOC. NO. 11 RECEIVED NYSCEF: 01/02/2018

FILED: NYS COURT OF CLAIMS 07/13/ :49 AM CLAIM NO NYSCEF DOC. NO. 4 RECEIVED NYSCEF: 07/13/2016

CHARLES N. INTERNICOLA, ESQ. CASE LITIGATION REPORT

ORDER TO SHOW. NYCTL TRUST, and THE BANK OF NEW YORK MELLON as Collateral Agent and Custodian for CAUSE

FILED: KINGS COUNTY CLERK 10/13/ :25 AM INDEX NO /2016 NYSCEF DOC. NO. 8 RECEIVED NYSCEF: 10/13/2016

FILED: NEW YORK COUNTY CLERK 01/10/ :47 AM INDEX NO /2016 NYSCEF DOC. NO. 75 RECEIVED NYSCEF: 01/10/2017

- UNITED STATES DISTRICT COURT,_. SOUTHERN DISTRICT OF NEW YORK

FILED: NEW YORK COUNTY CLERK 10/20/ :37 PM INDEX NO /2014 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 10/20/2014

FILED: NEW YORK COUNTY CLERK 04/20/ :16 PM INDEX NO /2016 NYSCEF DOC. NO. 26 RECEIVED NYSCEF: 04/20/2018

FILED: KINGS COUNTY CLERK 05/25/ /09/ :37 12:27 PM INDEX NO /2016 NYSCEF DOC. NO. 10 RECEIVED NYSCEF: 05/25/2016

FILED: BRONX COUNTY CLERK 12/14/ :42 AM INDEX NO /2016E NYSCEF DOC. NO. 57 RECEIVED NYSCEF: 12/14/2016

Appellate Term Docket Number: Upon the annexed affidavit of, dated, 2, and the papers annexed thereto,

Transcription:

At Part 8 of the Supreme Court of the State of New York, County of New York, Courthouse located at 71 Thomas Street, New York, NY 10007 on the day of November 2014. PRESENT: HON. JOAN KENNEY, J.S.C. -----------------------------------------------------------------X BPC ASSOCIATES, LP, -against- Plaintiff, Index No.: 152618-2014 ORDER TO SHOW CAUSE VITO LICARI and YAFFA SHEINA LICARI, -----------------------------------------------------------------X UPON THE READING AND FILING of the annexed affirmation of Brian J. Zimmet, Esq., dated the 6t~' day of November, 2014, and upon the proceedings had herein, DEFENDANTS ARE HEREBY ORDER TO SHOW CAUSE at Part 8 of the Supreme Court, County of New York to be held at the Courthouse located at 71 Thomas Street, New York, NY at a.m./p.m. on the day of, 2014, or as soon thereafter as counsel may be heard, why an ORDER should not be made and entered as follows: a. Granting the motion of Zimmet Bieber, LLP to withdraw and be relieved as the attorneys for Defendants; b. Staying all matters and proceedings in this action pending a determination of the within application and for a period of 30 days thereafter so as to permit Defendants an opportunity to retain new counsel; c. Granting such other further relief as may be just and proper. SUFFICIENT REASON APPEARING THEREFOR, it is: 1

ORDERED, that pending a hearing and determination of the within application, all further proceedings in this matter are hereby STAYED; and it is further ORDERED, that service of a copy of this ORDER and the papers upon which it was granted be made upon Defendants, VITO LICARI, at 1295 Fifth Avenue, Apt. 17G, New York, NY 10029 and YAFFA SHEINA LICARI, at 1295 Fifth Avenue, Apt. 17G, New York, NY 10029, by first class mail and via electronic mail on or before the _day of 2014, be deemed due and sufficient service; and it is further ORDERED, that service of a copy of this ORDER and the papers upon which it was granted be made upon Plaintiff's Counsel, Jeffrey A. Maidenbaum, Esq., Maidenbaum & Associates, PLLC, One Broadcast Plaza, Suite 218, Hetrick, NY 1156h by regular mail on or before the _day of, 2014 be deemed good and sufficient service. ENTER: J.S.0 2

SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF NEW YORK --------------------------------------------------------------- ---X BPC ASSOCIATES, LP, -agains~- Plaintiff, Index No.: 152618-2014 AFFIRMATION IN SUPPORT VITO LICARI and YAFFA SHEINA LICARI, ------------------------------------------------------X BRIAN ZIMMET, an attorney duly admitted to practice in the State of New York, affirms the following under penalties of perjury pursuant to the CPLR: 1. I am a member of Zimmet Bieber LLP, attorneys of record for VITO LICARI and YAFFA SHEINA LICARI, Defendants, in the instant action and have personal knowledge of the matters hereinafter set forth. I submit this affirmation in support of this firm's application to be relieved as counsel for 2. The instant motion is brought as a result of Defendants' refusal to communicate with our firm and assist in the defense of this matter. Defendants have also failed to pay our firm's legal fees in connection with services rendered in this matter. As a consequence, irreconcilable differences have developed between Defendants and the firm, causing a complete and irretrievable breakdown of the firm-client relationship. 3. No previous application for the relief sought herein has been made to this or any other Court. WHEREFORE, it is respectfully requested that this Court grant the motion of Zimmet Bieber LLP to withdraw from representation of the Defendants and for such other and further relief as this Court deems proper under the circumstances.

Dated: New York, NY November 6, 2014 Respectfully Submitted, 437 Madison Avenue, 40th Floor New York, NY 10022 (212) 922-1330

Year: 201~ Inds' No.: 152618 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF NEW YORK BPC ASSOCIATES LP, Plaintiff; -againstvito LICARI and YAFFA SHEINA LICARI, ORDER TO SHOW CAUSE ZIMMET BIEBER LLP Attorneys for' Defendants 437 Madison Avenue, 40`h Floor New York,lVew York 10022 (2l2} 922-1330 o: Atto~ ney(s) for Service of u copy of tfze tivithin is hereby admitted. Dated: pursuant to 22 NI'CRR 130-1.1, the z~ndej signerl, an attorney admitted to pf actice in the court ofnew York State, certifies t{aat upon information avrd belief and reasonable ingz~iry, the coratentio~as co~rtained in the annexed doci~fnent are not frivolous. Dated: Anjanagaur~i Koul, Esq. ZIMMET BtEBER LLP ~lttoineys for Defendant, Tasia Can2pbell 437 Madison Avenue, 40`h Floor To: Attorneys) for Plaintiff New York, New York 10022 (212) 922-1330