TRI PART: 21 NASSAU COUNTY

Similar documents
Plaintiff, Defendants.

TRI/IAS PART: 22 NASSAU COUNTY

Carlyle, LLC v Quik Park 1633 Garage LLC 2016 NY Slip Op 32476(U) December 15, 2016 Supreme Court, New York County Docket Number: /15 Judge:

PRELIMINARY STATEMENT

Gitlin v Chirinkin 2007 NY Slip Op 33860(U) November 21, 2007 Supreme Court, Nassau County Docket Number: / Judge: Stephen A.

FILED: KINGS COUNTY CLERK 06/01/ :49 PM INDEX NO /2017 NYSCEF DOC. NO. 2 RECEIVED NYSCEF: 06/01/2017

SUPREME COURT - STATE OF NEW YORK. HON. STEPHEN A. BUCARIA Justice

Defendant Mitchell Stern (Stern) moves, pursuant to CPLR 3212, for summary

Fran") and Camilo John Pesa ("Camilo ) (collectively "Plaintiffs ) oppose the motion. SUPREME COURT-STATE OF NEW YORK SHORT FORM ORDER Present:

Weitz v Weitz 2012 NY Slip Op 30767(U) March 19, 2012 Sup Ct, Nassau County Docket Number: Judge: Timothy S. Driscoll Republished from New

JMS AN's, LLC v Fast Food Enters., LLC 2011 NY Slip Op 33900(U) September 28, 2011 Supreme Court, New York County Docket Number: /09 Judge:

Zadar Universal Corp. v Lemonis 2018 NY Slip Op 33125(U) November 26, 2018 Supreme Court, New York County Docket Number: /2018 Judge: Gerald

Matter of Bethpage Fed. Credit Union v John 2011 NY Slip Op 31652(U) April 19, 2011 Supreme Court, Nassau County Docket Number: 20089/10 Judge:

Reid v Incorporated Vil. of Floral Park 2011 NY Slip Op 31762(U) June 21, 2011 Supreme Court, Nassau County Docket Number: 1981/11 Judge: Denise L.

Baron v Mason 2010 NY Slip Op 31695(U) June 30, 2010 Supreme Court, Nassau Court Docket Number: 02869/08 Judge: Randy Sue Marber Republished from New

STATE OF MICHIGAN COURT OF APPEALS

SUPREME COURT - STATE OF NEW YORK IAS TERM PART 12 NASSAU COUNTY

attchment, fied on February and submitted May 8, For the reasons set forth HON. TIMOTHY S. DRISCOLL Justice Supreme Court

Mr. San LLC v Zucker & Kwestel LLP 2012 NY Slip Op 32119(U) August 2, 2012 Sup Ct, Nassau County Docket Number: /11 Judge: Stephen A.

Jobar Holding Corp. v Halio 2018 NY Slip Op 31982(U) August 14, 2018 Supreme Court, New York County Docket Number: /2017 Judge: Saliann

Present: HONORABLE ORIN R. KITZES IA Part 17 Justice

Episcopal Health Servs. Inc. v Avery 2012 NY Slip Op 33880(U) November 30, 2012 Supreme Court, Nassau County Docket Number: /2012 Judge: Thomas

National Credit Union Admin. Bd. v Basin 2016 NY Slip Op 32456(U) December 13, 2016 Supreme Court, New York County Docket Number: /16 Judge:

SUPREME COURT STATE OF NEW YORK COUNTY OF NASSAU. PRESENT: HON. IRA B. WARSHAWSKY, Justice. TRIALIIAS PART 8. Plaintiffs INDEX NO.

SUPREME COURT - STATE OF NEW YORK HON. STEPHEN A. BUCARIA. Order to Show Cause... X Affidavit in Opposition... X Rep ly Affirmation...

FILED: NEW YORK COUNTY CLERK 05/20/ :15 PM INDEX NO /2016 NYSCEF DOC. NO. 2 RECEIVED NYSCEF: 05/20/2016

ARSR Solutions, LLC v 304 E. 52nd St. Hous. Corp NY Slip Op 30315(U) January 23, 2012 Supreme Court, Nassau County Docket Number:

Tulino v Tulino 2010 NY Slip Op 33431(U) December 2, 2010 Supreme Court, New York County Docket Number: /09 Judge: Stephen A.

FILED: KINGS COUNTY CLERK 03/22/ :32 PM INDEX NO /2017 NYSCEF DOC. NO. 57 RECEIVED NYSCEF: 03/22/2018

Lewis & Murphy Realty, Inc. v Colletti 2017 NY Slip Op 31732(U) July 25, 2017 Supreme Court, Queens County Docket Number: /2017 Judge: Robert

SUPREME COURT : STATE OF NEW YORK COUNTY OF NASSAU. Defendants.

State of New York Supreme Court, Appellate Division Third Judicial Department

RBK Doc#: 1231 Filed: 09/02/09 Entered: 09/02/09 15:11:43 Page 1 of 13

Tribeca Space Mgrs., Inc. v Tribeca Mews Ltd NY Slip Op 32433(U) December 23, 2015 Supreme Court, New York County Docket Number: /13

Wood v Long Is. Pipe Supply, Inc NY Slip Op 30384(U) February 5, 2010 Supreme Court, Nassau County Docket Number: Judge: Timothy S.

FILED: NEW YORK COUNTY CLERK 08/17/ :58 AM INDEX NO /2016 NYSCEF DOC. NO. 5 RECEIVED NYSCEF: 08/17/2016 SUPREME COURT OF THE STATE OF NEW

Herczi v Katan 2010 NY Slip Op 33052(U) October 25, 2010 Sup Ct, Nassau County Docket Number: Sup Ct, Nassau County Judge: Timothy S.

Plaintiff, Index No: Motion Seq. No: 1 Submission Date: 10/25/10

FILED: NEW YORK COUNTY CLERK 06/22/ :39 PM INDEX NO /2016 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 06/22/2016

INDEX NO /2010 NYSCEF DOC. NO. 595 RECEIVED NYSCEF: 12/30/2011

HON. TIMOTHY S. DRISCOLL Justice Supreme Court. Papers Read on these Motions: SUPREME COURT-STATE OF NEW YORK SHORT FORM ORDER Present:

Indo-Med Commodities, Inc. v Wisell 2014 NY Slip Op 33918(U) September 29, 2014 Supreme Court, Nassau County Docket Number: /14 Judge: F.

FILED: NEW YORK COUNTY CLERK 07/11/ :13 PM INDEX NO /2010 NYSCEF DOC. NO. 548 RECEIVED NYSCEF: 07/11/2016

THOMAS CATANESE Defendants x

RBS Citizens, N.A. v Barnett 2010 NY Slip Op 31971(U) July 16, 2010 Sup Ct, Nassau County Docket Number: Judge: Timothy S.

Emigrant Bank v Greene 2015 NY Slip Op 31343(U) February 24, 2015 Supreme Court, Queens County Docket Number: /2014 Judge: Allan B.

Benedetto v Mercer 2012 NY Slip Op 33347(U) July 30, 2012 Supreme Court, New York County Docket Number: /2012 Judge: Ellen M.

Lattarulo v Industrial Refrig., Inc NY Slip Op 32423(U) May 22, 2018 Supreme Court, Nassau County Docket Number: /17 Judge: Thomas

Gall v Colon-Sylvan 2012 NY Slip Op 33931(U) November 9, 2010 Supreme Court, Nassau County Docket Number: 6536/07 Judge: Stephen A.

Sina Drug Corp. v Mohyuddin 2010 NY Slip Op 30383(U) February 11, 2010 Supreme Court, Nassau County Docket Number: /2006 Judge: Ira B.

Blatt v Ashkenazi 2010 NY Slip Op 33432(U) December 2, 2010 Supreme Court, New York County Docket Number: 9556/07 Judge: Stephen A.

Orlinsky v GEICO Ins. Co NY Slip Op 30905(U) February 25, 2011 Supreme Court, Nassau County Docket Number: /10 Judge: F.

Plaintiff, Defendants.

Neiditch v William Penn Life Ins. Co. of N.Y NY Slip Op 32757(U) April 24, 2015 Supreme Court, Nassau County Docket Number: /14 Judge:

Case 1:12-cv SLT-VVP Document 23 Filed 03/31/14 Page 1 of 7 PageID #: 306. Plaintiffs, 12-CV-1428 (SLT)(VVP)

Case: 4:15-cv RWS Doc. #: 30 Filed: 05/04/15 Page: 1 of 2 PageID #: 183

MA DAYAN, EMPIRE HOME SALES, INC., ASAF DROR, ESQ., JOHN DOE MORTGAGE BROKER, SUPERIOR ABSTRACT CORP.,

The Statute of Limitations Under the Uniform Fraudulent Transfer Act: New Jersey s View

PRESENT: The unopposed motion by Plaintiff NATIONAL CONTINENTAL INSURANCE SHAMALL BREWSTER, KIGS COUNTY MEDICAL. Defendants EMEKA ADIGWE

International Union of Bricklayers & Allied Craftworkers v Bank of New York Mellon 2014 NY Slip Op 30177(U) January 17, 2014 Supreme Court, New York

Fulton Commons Care Ctr. v Belth 2010 NY Slip Op 32533(U) September 9, 2010 Supreme Court, Nassau County Docket Number: Judge: Timothy S.

Trial/IS FORWAR DOOR OF NEW YORK INC. IRWI FORLADER CRAG FORLADER, FORWAR DOOR COMPAN

SHORT FORM ORDER SUPREME COURT OF THE STATE OF NEW YORK

Short Form Order NEW YORK SUPREME COURT - QUEENS COUNTY

Young v Quatela 2010 NY Slip Op 31607(U) June 18, 2010 Supreme Court, Nassau County Docket Number: /09 Judge: Thomas Feinman Republished from

SUPREME COURT - STATE OF NEW YORK. HON. STEPHEN A. BUCARIA Justice

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

Reilly v Garden City Union Free School Dist NY Slip Op 32871(U) December 1, 2009 Supreme Court, Nassau County Docket Number: 9968/09 Judge:

Poten & Partners Inc. v Greco 2015 NY Slip Op 32266(U) November 30, 2015 Supreme Court, New York County Docket Number: /2010 Judge: Saliann

Order to Show Cause, dated Notice of Cross Motion, dated Affirmation in Reply & Opposition to Cross Motion, dated

SUPREME COURT STATE OF NEW YORK COUNTY OF NASSAU. Defendants. Motion by the defendants Victor Barouh and Barouh Eaton Allen Corp.

Bloostein v Morrison Cohen LLP 2017 NY Slip Op 31238(U) June 7, 2017 Supreme Court, New York County Docket Number: /2012 Judge: Anil C.

Siegal v Pearl Capital Rivis Ventures LLC 2018 NY Slip Op 30256(U) February 13, 2018 Supreme Court, New York County Docket Number: /2013 Judge:

SUPREME COURT THKSTATE NEW.YORK COUNTY OF NASSAU. Plaintiff, Third-Party Plaintiff, Third-Party Defendant.

FILED: NEW YORK COUNTY CLERK 03/10/ :35 PM INDEX NO /2017 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 03/10/2017

Order to Show Cause, Affirmation in Support and EJ(hibits... Affirmation in Opposition and EJ(hibits...

HON. TIMOTHY S. DRISCOLL Justice Supreme Court. The following papers having been read on these motions:

Rosenberg v Hedlund 2016 NY Slip Op 30201(U) February 4, 2016 Supreme Court, New York County Docket Number: /2015 Judge: Eileen A.

( Debtor ), the debtor in the above-captioned Chapter 7 case, by his attorneys, Pryor & Mandelup,

SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF NASSAU. Plaintiff,

Plaintiff, Defendants.

Hirani Eng'g & Land Surveying, P.C. v Long Is. Bus. Solutions, Inc NY Slip Op 30970(U) April 1, 2011 Supreme Court, Nassau County Docket

Pielet Bros. Contr. v All City Glass'n Mirro-1964UA, LLC 2015 NY Slip Op 31045(U) June 18, 2015 Supreme Court, New York County Docket Number:

Burnett v Pourgol 2010 NY Slip Op 30250(U) January 26, 2010 Supreme Court, Nassau County Docket Number: 13130/09 Judge: Stephen A.

SUPREME COURT OF THE STATE OF NEW YORK. Respondents. The followine papers have been read on these motions:

NOTICE OF DEADLINE REQUIRING FILING PROOFS OF CLAIM FOR ADMINISTRATIVE EXPENSE CLAIMS

In this matrimonial proceeding, defendant-wife seeks to have the court use its civil

Hudson Realty Assoc., LLC v New Generation Hair Desing, Corp 2018 NY Slip Op 33048(U) December 5, 2018 Supreme Court, New York County Docket Number:

mew Doc 354 Filed 08/19/16 Entered 08/19/16 10:23:03 Main Document Pg 1 of 15

Curran v Brookstone Co., Inc NY Slip Op 32656(U) September 29, 2011 Sup Ct, Nassau County Docket Number: 13594/10 Judge: F.

SUPREME COURT OF THE STATE OF NEW YORK. Plaintiff. Defendant x

Matter of Gohil v Gohil 2012 NY Slip Op 30320(U) January 23, 2012 Supreme Court, Nassau County Docket Number: Judge: Timothy S.

IN THE CIRCUIT COURT OF JEFFERSON COUNTY STATE OF MISSOURI ASSOCIATION DIVISION

FILED: NASSAU COUNTY CLERK 12/22/ :59 AM

Emil LLC v Jacobson 2018 NY Slip Op 32529(U) October 3, 2018 Supreme Court, New York County Docket Number: /2017 Judge: Barry Ostrager Cases

Shi v Shaolin Temple 2011 NY Slip Op 33821(U) July 1, 2011 Sup Ct, Queens County Docket Number: 20167/09 Judge: Denis J. Butler Cases posted with a

Ganzevoort 69 Realty LLC v Laba 2014 NY Slip Op 30466(U) February 25, 2014 Supreme Court, New York County Docket Number: /2013 Judge: Eileen A.

shl Doc Filed 02/13/15 Entered 02/13/15 17:11:28 Annex I Pg 2 of 6

Present: HON. GEOFFREY J. O CONNELL Justice. Defendant(s). MOTION SEQ. No. 2

Gliklad v Kessler 2016 NY Slip Op 31301(U) July 7, 2016 Supreme Court, New York County Docket Number: /2014 Judge: Anil C. Singh Cases posted

Transcription:

.... SUPREME COURT - STATE OF NEW YORK Present: HON. ARTHU M. DIAMOND Justice Supreme Court ----------------------------------------------------------------------- x SEBASTIA LATTUGA TRI PART: 21 NASSAU COUNTY -against- CLAUDIO D' CHIUTIIS, PAULINE CHIUTIIS-LATTUGA, CD AUTOS, INC., ALL ISLAND MOTORS, CORP. AND P&C Motors, LLC Defendant. ------------------------------------------------------------------------ x The following papers having been read on this motion: Plaintiff, INDEX NO: 001419/07 MOTIQN SEQ. NO: 02 SUBMIT DATE:1I29/08 Notice of Motion... 1 Opposition Rep Iy...... The plaintiff and defendant Pauline D' Chiutiis- Lattga wer maried on December 27, 1996. Defendant' s father, co-defendant Claudio D' Chiutiis has been the pwnerofvarous companies that own and operate successful automobile dealerships in the County of Nassau. On Januar 2 2001 Claudio D' Chiutiis sold, transferred and conveyed 100% of the issued outstanding shares of stock in defendant CD Auto to defendant Pauline D' Chiutiss-Lattga for a purchase price of$i 4000 with $150 000 to be paid as a down payment and the balance in 60 equal monthly installments of $24 166 secured by 60 promissory notes. Plaintiff claims in th complaint. that he provided the fuding to defendant Pauline D'Chiutiss-Lattuga to purchase said company and to make the installment payments. In retur, plaintiff claims that defendant, Pauline D' Chiutiss-Lattga promised and agreed that her shares of CD Auto, and the other corporate defendants, All Island Motors Corp, and P&C Motors, LLC would be jointly owned by the two of them. Plaintiff claims that he gave a total of$784 822.00 to the defendant Pauline D' Chiutiss-Lattuga which were paid to Claudio D' Chiutiis. Plaintiff claims that defendant Pauline D' Chiutiss-Lattga and co-defendant Claudio D' Chiutiis entered into similar agreements concerning the stock of All Island Motors, and

P&C Motors. According to plaintiffs complaint, on or about June 29 2004, the defendant-wife Pauline D' Chiutiss-Lattuga, intentionally defaulted in payments on the promissory notes, and transferred the stocks of the defendant corporations to Claudio D' Chiutiss, thereby relinquishing control and ownership without consideration in order to deprive plaintiff of the assets. Defendantwife, Pauline D' Chiutiss-Lattuga, commenced a matrimonial actiqn against the plaintiff seeking a divorce on Januar 5, 2005. In the context of that matrmonial action, defendant states that she does not have ownership in the corporate defendants' CD Auto, All Island Motors, and P&C Motors for purposes of determining equitable distribution. Plaintiff has commenced this instant action claiming that h,e has a a constrctive trst over the defendant corporations, and has moved to set aside the conveyances alleging that it was fraudulent under Aricle 10 of the Debtor Creditor Law. Defendants, Claudio D' Chiutiss, CD Auto, All Island Motors, and P&C Motors had moved for an order dismissing the complaint in its entirety pursuant to CPLR 93211 (a) (1), a defense based upon documentar evidence, and for failure to state a cause of actiqj? under CPLR 93211 (a) (7). The court issued an order dated November 28 2007 granting dismis al of the first, second, thrd and fourth causes of action, and denying dismissal of the remaining cau es of action. Likewise, co-defendant Pauline D' Chiuttis- Lattga, the wife of plaintiff, has now moved for an order to dismiss the complaint upon the same grounds. In a defense based upon documentar evidence, the documentar evidence presented by defendants must "utterly refu " the plaintiff s allegations and establish a defense as a matter oflaw. (Goshen v. Mutual Life Ins. Co. OfN Y. 98 N.Y.2d 314). The docwnentary evidence must be such that it resolves all factual issues as a matter of law and definitively disposes of plaintiffs claim (Teiter v. Max J Pollack Sons 288 A.D.2d 302 J. In deciding a motion to dismiss for failure to state a cause of action, the complaint is to be liberally construed, and the cour is required to view every allegation of the complaint as true, and resolve all inferences in favor of plaintiff regardless of whether plaintiff wil ultimately prevail on the merits. Each cause of action set forth in the complaint must contain factual allegations, and not legal conclusions, establishing elements of same. (Arnav Indus., Inc. Retirement Trust v. Brown Raysman, Milstein, Felder Steiner, LLP 96 N. Y.2d 300; Grand Realty Co. V. City of White Plains 125 A. 2d 639).

The defendant' s motion for an order to dismiss the first c use of action alleging a constructive trust is denied. Plaintiff has set fort facts in the complaint, assuming they are true establishing the four elements of a constructive trust which are 1) a confidential or fiduciar relationship; 2) a promise; 3) a breach of that promise; and 4) defendants ' unjust enrichment as a result of his or her actions. (Potter v. Davis 275 A.D.2d 961). In regards to the second cause of action under DCL 9273, the third cause of action under DCL 9274, and the fourh cause of action under DCL 9275, allegin a constructive fraudulent conveyance of the stock of the corporations where the conveyancq i made without fair consideration by a person (1) who is insolvent or will be rendered insolvent (DCL 9273); or (2) who is engaged in a business for which capital is uneasonably small (DCL 9274), or (3) who believes he wil incur debts beyond his/her abilty to pay (DCL 9 75); those causes of actions are hereby dismissed pursuant to CPLR 93211 (a) (7). There are insufficient factual allegations specified in thes thee causes of actions to establish the requisite elements of that paricular cause of action to fraudulent conveyance. stablish a constrctive In the second cause of action, plaintiff has failed to alleg any facts showing that defendant Pauline D' Chiutiss-Lattuga was insolvent or rendered insolvent at the time of the conveyances. (Galgano v. Ortiz 287 A.D.2d 688). The third CaU1 y qf action fails to set forth facts that defendant Pauline D' Chiutiss-Lattga was engaged in a business for which capital is uneasonably small under DCL 9274, other than the legal conclusory statement as to such in the complaint. Also, the four cause of action fails to set forth facts showing that defendant Pauline Chiutiss-Lattuga made the conveyances intending or believing that she will incur debts beyond the abilty to pay as they mature pursuant to DCL 9275. However, the plaintiff has set forth a sufficient cause of aqtipn for an actual fraudulent" conveyance pursuant to DCL 9276 under the fifth cause of action of the complaint. Debtor and Creditor Law 9276 provides that "Every conveyance made and every obligation incured with actual intent, as distinguished from intent presumed in law, to hinder, delay, or defraud either present or future creditors, is fraudulent as to both present and futue creditors. (McKinney Cons. Laws ofn., Vol. 12, DCL 9276, at 352). The defendants' contention that the plaintiff is not a creditor is without merit. A creditor

is defined under section 270 of the Debtor and Creditor Law as "a person having any claim whether matured, or unmatured, liquidated, or unliquidated, absolute, fixed or contingent." (McKinney s Cons. Laws ofn., Vol. 12, DCL 9270, at 284) A pouse is a creditor to his/her spouse as to any present or futue support payments or equitable distribution of assets in a pending divorce even though the claim may be unatued and unliquidated at the time ofthe conveyance. (Kasinski v. Questel 99 A.D.2d 396, where transfer of martal residence by husband to girlfriend in contemplation of divorce was fraudulent under the Debtor and Creditor Law; Saldano v. Saldano, 66 A. 2d 839, whereby husband' s transfer pfthree parcels of real estate to his brothers in contemplation of divorce was fraudulent under th Debtor and Creditor Law since wife was a creditor of necessaries and future alimony award) The factual allegations set forth in the complaint, if tre, show an actual intent by the defendant to take par in a scheme to hinder, delay, or defraud plaintiff, as a creditor, pursuant to DCL 9276, from receiving his portion of the businesses, or a credit for same, as equitable distribution if defendant Pauline D' Chiutiss-Lattuga was the actu l owner or parial owner of said businesses during the mariage. Debtor and Creditor Law 276! unlike sections DCL 9273 274 and 9275, addresses actual fraud, and not constrctive fraud, and does not require proof of unfair consideration or insolvency. Due to the :diffculty of proving actual intent to hinder, delay, or defraud creditors, the pleader is allowed to rely on "badges offraud" to support his case, i.e. circumstances so commonly associated with fraudulent transfers that their presence gives rise to an inference of intent. (Wall Street Associates v. Brodsky, 257 A.D. d 526; See, AMP Services Ltd. v. Walanpatrias Foundation 34 AD.3d 231). Some ofthe circumstaces to be considered are (1) a close relationship between the paries to the alleged fraudulent transaction, (2) a questionable transfer not in the usual course of business; (3) inadequacy ofthe consideration;(4) transferor s knowledge ofthe creditors claim aid the inabilty to pay it; and (5) retention of control of the propert by the transferor after the conveyance. (Wall Street Associates v. Brodsky, at 529). Here, if the plaintiffs allegations in the complaint are proven tre at tral by clear and convincing evidence: the intentional default of the promissory notes by defendant Pauline Chiutiss-Lattuga, the conveyances of ownership of the corporations by the defendant Pauline Chiutiss-Lattuga to her father Claudio D' Chiutiss, the conveyances were made six months before the commencement of the matrimonial action made in anticipation of fiing divorce to

,,. prevent plaintiff from recovering his share of the equitable distribution of these alleged marital assets, and defendant Pauline D' Chiutiss-Lattga has stil maintain d control of said entities with her co-defendant father, Claudio D' Chiutiss, are all circumstances constituting "badges of fraud. (See, Kasinski supra, at 397-398). The documentation provided by defendant does not "utterly" refute plaintiff s claim as to establish a complete defense to this cause of action. The defendant's motion to dismiss the remaining causes of action pursuant to CPLR 93211 is denied in its entirety. Accordingly, the second, third, and fourh causes of action in the complaint are hereby dismissed as against the defendant Pauline D' Chiuttis-Lattuga. This constitutes the decision and order of this Cour. DATED: February 26 2008 To: Attorney for Plaintiff ANTHONY A. CAPETOLA, ESQ. Two Hilside Ave.. Bldg. C. Wiliston Park, NY 11596-2335 (516) 746-2300 VIA FAX: (516) 746-2318 Attorney for Remaining Defendants JONATHAN M. CADER, ESQ. HESSION, BECKOFF & Cooper, LLP. 1103 Stewart Avenue Suite 200 Garden City, New York 11530 (516) 408-3666 cqed \"f\r 0 5 1008 Attorney f()r Plaintiff JOHN A. P;\PPALARpp FARER f ;\PP ALA CARBONAR COUNi'l 200 East PQst Road Whte Plains, New York 10601 Attorney for Defendant Pauline Chiutis8-Lattuga VITO PALMIERI, ESQ. ALMIEJU & CASTIGLIONI, LLP 250 Mineola Boulevard Mineola, New York 11501 (516) 248-9595 0uNTY.. CLERK' SQFFICE