You're viewing Docket Item 9 from the case Cornwall Management Ltd. et al v. Thor United Corp. et al. View the full docket and case details.

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CORNWALL MANAGEMENT LTD and OLEG
SOLOVIEV a/k/a OLEG VALENTINOVICH
SOLOVIEV,


Plaintiffs,

-against-


THOR UNITED CORP. a/k/a THOR UNITED
CORPORATION, JOHN DOE THOR
ENTITIES, ATLANTA CAPITAL HOLDINGS,
LLC, OLEG BATRACHENKO a/k/a
O.V.BATRACHENKOV, PETER KAMBOLIN,
NORTH 3RD DEVELOPMENT, LLC, and
ABRAHAM BENNUN


Defendants.







Case 1:12-cv-08551-LLS Document 9 Filed 03/13/13 Page 1 of 2



UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK


12 CIV 08551 (LLS)





NOTICE OF MOTION



PLEASE TAKE NOTICE that upon the accompanying Memorandum of Law in Support

of Motion to Dismiss the Amended Complaint, dated March 13, 2013; the annexed Declaration

of Renee M. Zaytsev, dated March 13, 2013, and the exhibits thereto; and upon all pleadings and

proceedings had herein, defendants Abraham Bennun and North 3rd Development, LLC will

move this Court before the Honorable Louis L. Stanton, United States District Judge at the

United States Courthouse, 500 Pearl Street, New York, New York 10007 on a date and time to

be set by the Court, for an Order dismissing the Amended Complaint pursuant to Fed. R. Civ. P.

12(b)(6) and 9(b), and for such other and further relief as the Court deems just and proper.


2003329-1

Case 1:12-cv-08551-LLS Document 9 Filed 03/13/13 Page 2 of 2



March 13, 2013

Dated: New York, New York











OLSHAN FROME WOLOSKY LLP


By:


/s/ Renee M. Zaytsev
Thomas J. Fleming
Renee M. Zaytsev
Attorneys for Defendants
Abraham Bennun and North 3rd
Development, LLC
Park Avenue Tower
65 East 55th Street
New York, New York 10022
(212) 451-2300


2003329-1