Opinion
21 Civ. 1987 (RA)
12-27-2021
ERICA BARTMAN, Plaintiff v. L'OFFICIEL USA INC., GLOBAL EMERGING MARKETS NORTH AMERICA INC., and JALOU PUBLISHING, INC. d/b/a JALOU MEDIA GROUP, Defendants
VENTURINI & ASSOCIATES August C. Venturini Attorneys for Defendants Kenneth T. Kerner, Esq. KERNER & KERNER, P.C. Attorneys for Plaintiff
VENTURINI & ASSOCIATES
August C. Venturini
Attorneys for Defendants
Kenneth T. Kerner, Esq.
KERNER & KERNER, P.C.
Attorneys for Plaintiff
NOTICE OF MOTION TO DISMISS THE COMPLAINT AND TO STRIKE THE JURY DEMAND
HON. RONNIE ABRAMS
PLEASE TAKE NOTICE that, upon the annexed Declaration of August C. Venturini, dated December 3, 2021, and all exhibits annexed thereto, the Memorandum of Law in Support, and upon all prior proceedings, pleadings and papers had or filed herein, Defendants L'Officiel USA Inc., Global Emerging Markets North America Inc., and Jalou Publishing, Inc. will move this Court, before the Honorable Ronnie Abrams, at the United States Courthouse for the Southern District of New York, at 40 Foley Square, New York, New York, Courtroom 1506, on Monday, January 24, 2022 at 9:30 a.m., or as soon thereafter as counsel may be heard, for an Order, dismissing the Complaint with prejudice, and striking the jury demand, pursuant to Federal Rules of Civil Procedure 12(b)(6) and 12(f), together with such other and further relief as to this Court may seem just and proper.
PLEASE TAKE FURTHER NOTICE that, pursuant to a stipulation between the parties, opposition papers are due on January 7, 2022 and reply papers are due on January 21, 2022.
VENTURINI & ASSOCIATES
August C. Venturini
Attorneys for Defendants
TO:
Kenneth T. Kerner, Esq.
KERNER & KERNER, P.C.
Attorneys for Plaintiff
Consistent with the Court's Individual Rules, if the parties are requesting oral argument on this motion, they must notify the Court in writing.
SO ORDERED.