|CONGREGATION BNAI MOSES JOSEPH ZANICHOST and ZOSMER,
RALPH FELDMAN, iSAAC FRIED, and CLAYTON PATTERSON,
Index number 108322/1995
|PLEASE TAKE NOTICE, that upon the
annexed affirmatiion of Sidney Turkeltaub the President of the Plaintiff,
sworn on the 18th day of June, 1996, and upon the annexed Memorandum of
Law submitted by HOWARD SCHNEIDER & ASSOCIATRES, the attorney for plaintiff
in support of this instant motion and the Answer of defendant Feldman filed
and the Affiidavits of Asher Fogel, Moss Fogel, Ray
Owens and Leo Goldblum filed herein, the Summons and Complaing together
with all other papers filed herein, plaintiff Congregation Bnei Moses Joseph
Anshei Zawichost and Zosmer, Inc., shall move this Court at Room 13() of
this Court located at the Courthouse at 60 Centre Street, new York, New
York, on the 16th day of July, 1997 at 9:30 a.m. or as soon thereafter
as counsel could gbe heard, for an Orderpursuant to CPLR 3212 for partial
Summary judgment as there exists no triable issue of fact as to the issues
raised in the complaint save the issue for monetary damages together with
such other and further relief that this Court deems just and proper.
Why has my (Clayton Patterson) "Answer" never been
acknowledged by the Plaintiffs?
Responding papers, if any, should be served within
the time required by CPLR 2214.
The plaintiffs have never repsonded to anyor acknowledged
any paper that I, Clayton Patterson, subgmitted to them.
HOIWARD SCHNEIDER & ASSOCIATES
ATTORNEY FOR PLAINTIFF
15 PARK ROW
NEW YORK, NEW YORK 10038
MARK D. POGOSTIN, ESQ.
ATTORNEY FOR DEFENDANT RALPH FELDMAN
305 NORTH AVENUE
NEW ROCHELLE, NY 10801
161 ESSEX STREET
NEW YORK, NY 10002
1423 AVENUE I
BROOKLYN, NY 11230