PlainSite :: William Moran II v. Newsweek LLC et al, Supreme Court of the State of New York, New York County Case No. 151179/2017 Document 37: NOTICE OF MOTION (Motion #004)

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INDEX NO. 151179/2017

FILED: NEW YORK COUNTY CLERK 05/25/2017 05:52 PM
NYSCEF DOC. NO. 37

RECEIVED NYSCEF: 05/25/2017

SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF NEW YORK

------------------------------------------------------------------X :

WILLIAM MORAN II,

Plaintiff, :

-against:

NEWSWEEK LLC and IBT MEDIA, INC., :

Defendants.

Index No.: 151179/2017 Justice Arlene P. Bluth Mot. Seq. No. 4 NOTICE OF MOTION ORAL ARGUMENT REQUESTED

------------------------------------------------------------------X PLEASE TAKE NOTICE, that upon the Affirmation of David S. Bralow, executed on the 25th day of May, 2017, and the accompanying memorandum of law, Defendants Newsweek LLC and IBT Media, Inc. will move this Court, on the 8th day of August, 2017, at 9:30 a.m. in the forenoon of that day, or as soon after that as the parties may be heard, at the Motion Submission Part Courtroom, Room 130, at the Courthouse located at 60 Centre Street, New York, New York 10007, for an Order pursuant to CPLR 3211(a)(7) dismissing the Second Amended Complaint with prejudice, together with such other and further relief as the Court deems appropriate.

PLEASE TAKE FURTHER NOTICE, that pursuant to the stipulation entered into by the Parties, answering papers, if any, are required to be served upon the undersigned by July 7, 2017 and reply papers, if any, are required to be served upon Plaintiff by August 4, 2017. (See Doc. No. 23.)

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INDEX NO. 151179/2017

FILED: NEW YORK COUNTY CLERK 05/25/2017 05:52 PM NYSCEF DOC. NO. 37

RECEIVED NYSCEF: 05/25/2017

Dated: New York, New York May 25, 2017

David S. Bralow PEPPER HAMILTON LLP The New York Times Building 620 Eighth Avenue New York, NY 10018-1405

(212) 808-2710 Eli Segal (pro hac vice motion submitted) Eric S. Merin PEPPER HAMILTON LLP 3000 Two Logan Square Eighteenth and Arch Streets Philadelphia, Pennsylvania 19103-2799

(215) 981-4239 Counsel for Defendants Newsweek LLC and IBT Media, Inc. To: William Moran II (Pro Se) 1140 23rd Street NW Washington, DC 20037

(208) 242-8413

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PDF Page 2	INDEX NO. 151179/2017 FILED: NEW YORK COUNTY CLERK 05/25/2017 05:52 PM NYSCEF DOC. NO. 37 RECEIVED NYSCEF: 05/25/2017 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF NEW YORK ------------------------------------------------------------------X : : WILLIAM MORAN II, : Plaintiff, : : -against: : : NEWSWEEK LLC and IBT MEDIA, INC., : : Defendants. Index No.: 151179/2017 Justice Arlene P. Bluth Mot. Seq. No. 4 NOTICE OF MOTION ORAL ARGUMENT REQUESTED ------------------------------------------------------------------X PLEASE TAKE NOTICE, that upon the Affirmation of David S. Bralow, executed on the 25th day of May, 2017, and the accompanying memorandum of law, Defendants Newsweek LLC and IBT Media, Inc. will move this Court, on the 8th day of August, 2017, at 9:30 a.m. in the forenoon of that day, or as soon after that as the parties may be heard, at the Motion Submission Part Courtroom, Room 130, at the Courthouse located at 60 Centre Street, New York, New York 10007, for an Order pursuant to CPLR 3211(a)(7) dismissing the Second Amended Complaint with prejudice, together with such other and further relief as the Court deems appropriate. PLEASE TAKE FURTHER NOTICE, that pursuant to the stipulation entered into by the Parties, answering papers, if any, are required to be served upon the undersigned by July 7, 2017 and reply papers, if any, are required to be served upon Plaintiff by August 4, 2017. (See Doc. No. 23.) 1 of 2

PDF Page 3	INDEX NO. 151179/2017 FILED: NEW YORK COUNTY CLERK 05/25/2017 05:52 PM NYSCEF DOC. NO. 37 RECEIVED NYSCEF: 05/25/2017 Dated: New York, New York May 25, 2017 David S. Bralow PEPPER HAMILTON LLP The New York Times Building 620 Eighth Avenue New York, NY 10018-1405 (212) 808-2710 Eli Segal (pro hac vice motion submitted) Eric S. Merin PEPPER HAMILTON LLP 3000 Two Logan Square Eighteenth and Arch Streets Philadelphia, Pennsylvania 19103-2799 (215) 981-4239 Counsel for Defendants Newsweek LLC and IBT Media, Inc. To: William Moran II (Pro Se) 1140 23rd Street NW Washington, DC 20037 (208) 242-8413 2 of 2

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William Moran II v. Newsweek LLC et al Document 37: NOTICE OF MOTION (Motion #004)