XXX DISTRICT COURT
EASTERN DISTRICT OF XXX
……………………………………………………………………..X
In re:
Chapter 7
XXX, Case No.: XXXX
Debtor.
……………………………………………………………………..X
XXX,
Plaintiff,
v.
DARROW ARONOW, ESQ., HANIN R. SHADOOD, Adv. Pro. No: XXXX
COURTNEY R. XXX,, ESQ., FAY SERVICING
LLC, XXX LOAN MANAGEMENT SERVICES,
INC., XXXXX, THE XXXX
OF XXX, DOES 1-100 INCLUSIVE
Defendants.
……………………………………………………………………..X
NOTICE OF MOTION
To ALL Defendants and to ALL Attorneys of Record:
Please TAKE NOTICE that on August XXX, at XXX a.m. or soon thereafter, the
Plaintiff herein will move this Court for an Order for a Reconsideration of the Court’s decision
dated March XXX, which granted Defendants’ Motions to Dismiss Plaintiff’s adversary
complaints, and for such other and further relief as this Court deems just and proper.
The Motion for Reconsideration will be based on the grounds that Plaintiff’s Complaint
contains sufficient factual matter to state a claim of relief that is plausible on its face; Courts
have ruled that a motion to dismiss under rule 12(b) is disfavored and is rarely granted;
Dismissal of a complaint without leave to amend is improper unless it is clear that the complaint
cannot be saved by any amendment; and the Court abused its discretion.
2
Further, the motion will be based on this Notice of Motion, the points, arguments, and
authorities in support of the Motion, on the records and file herein, and on such evidence as may
be presented at the hearing of the motion.
Respectfully submitted,
Date: _________________
XXX
Pro Se Debtor
3
CERTIFICATE OF SERVICE
I certify that a copy of this Motion for Reconsideration was served on [ENTER DATE] to the
Defendants in this action at the following addresses:XXX4
200 Business Park Drive, Ste 103
Armonk, NY 10504
Counsel for Rushmore Loan Management Services, Inc.
DATE:
XXX
Pro Se Debtor
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