`
`UNITED STATES DISTRICT COURT
`SOUTHERN DISTRICT OF NEW YORK
`----------------------------------------------------------------------- x
`
`JUSTIN SAMUELS,
`
`-against-
`
`CITY OF NEW YORK,
`
`
`
`Plaintiff,
`
`NOTICE OF MOTION TO
`DISMISS
`PLAINTIFF’S
`COMPLAINT
`
`No. 23-cv-10045 (AS)
`
`
`
`Defendant.
`
`----------------------------------------------------------------------- x
`
`TAKE NOTICE that, upon the accompanying Memorandum of Law in Support
`
`of the City of New York’s Motion to Dismiss Plaintiff’s Complaint, dated September 6, 2024,
`
`the Declaration of Sarah O’Connell in Support of Defendant’s Motion to Dismiss the Complaint
`
`and upon all other papers and proceedings heretofore had herein, Defendant City of New York,
`
`by and through its attorney, Muriel Goode-Trufant, Acting Corporation Counsel of the City of
`
`New York, will move this Court before the Honorable Arun Subramanian of the United States
`
`District Court for the Southern District of New York at the United States Courthouse located at
`
`500 Pearl Street, New York, New York 10007, on a date and time to be determined by the Court,
`
`for an order, pursuant to Rule 12(b)(1) of the Federal Rules of Civil Procedure, dismissing the
`
`claims against the City of New York in the Complaint, denying all relief sought therein, and
`
`granting such other and further relief to the Defendant City of New York as the Court may deem
`
`just and proper.
`
`
`
`
`
`Case 1:23-cv-10045-AS Document 32 Filed 09/06/24 Page 2 of 2
`
`TAKE FURTHER NOTICE that, pursuant to Section 6(A) of the Individual
`
`Practices in Civil Pro Se Cases of the Honorable Arun Subramanian, Plaintiff shall serve his
`
`papers in opposition to this motion within 30 days, or by October 7, 2024, and that the Defendant
`
`City of New York shall serve its reply papers, if any, within two weeks after receipt of Plaintiff’s
`
`papers in opposition, or by October 21, 2024.
`
`Dated:
`
`September 6, 2024
`New York, New York
`
`MURIEL GOODE-TRUFANT
`Acting Corporation Counsel of the City of New York
`Attorney for Defendant City of New York
`100 Church Street
`New York, NY 10007
`(212) 356-4362
`johdoody@law.nyc.gov
`
`
`
`
`
`/s/
`
`John Doody
`Assistant Corporation Counsel
`
`
`
`
`
`
`
`By:
`
`To:
`
`Justin Samuels (via ECF)
`Plaintiff pro se
`120 Laketa Drive
`Gallion, AL 36748
`929-435-2262
`Email: nywriter55@outlook.com
`
`
`
`
`
`-2-
`
`
`
`
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