Darryl West
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5650 Carpenter Road
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Ypsilanti, MI 48197
(734) 961-2493
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darrylsfamily2@gmail.com
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Joseph West
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5650 Carpenter Road
Ypsilanti, MI 48197
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(734) 961-2493
darrylsfamily2@gmail.com
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Plaintiff in pro per
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STATE OF MICHIGAN
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IN THE 34TH DISTRICT COURT
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FOR THE COUNTY OF WAYNE
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DARRYL WEST; AND JOSEPH WEST, 15
Plaintiff,
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vs.
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GREGG GERAGOCIAN; AND I-94 MARINE & WATERSPORTS,
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Defendant
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Case No.: 21-3459 GC
Hon. Tina Brooks Green
PLAINTIFF’S MOTION TO WAIVE SERVICE TO GREGG GERAGOCIAN
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NOTICE OF MOTION TO WAIVE SERVICE TO GREGG GERAGOCIAN
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You are notified that on [DATE] at [TIME], or as soon thereafter as the Plaintiff can be heard, in 24
Courtroom ___ of the 34th District Court for the County of Wayne at [ADDRESS], the Plaintiff 25
will bring on for hearing his Motion to Waive Service to Gregg Geragocian for the reasons stated 26
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in the attached Motion.
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PLAINTIFF’S MOTION TO WAIVE SERVICE TO GREGG GERAGOCIAN – 1
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Dated this [DATE] day of [MONTH], 2021.
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Respectfully Submitted,
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___________________________________
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Darryl West
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Plaintiff in pro per
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___________________________________
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Joseph West
Plaintiff in pro per
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PLAINTIFF’S MOTION TO WAIVE SERVICE TO GREGG GERAGOCIAN – 2
Darryl West
1
5650 Carpenter Road
2
Ypsilanti, MI 48197
(734) 961-2493
3
darrylsfamily2@gmail.com
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Plaintiff in pro per
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STATE OF MICHIGAN
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IN THE 34TH DISTRICT COURT
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FOR THE COUNTY OF WAYNE
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DARRYL WEST,
Plaintiff,
vs.
I-94 MARINE & WATERSPORTS, Defendant
Case No.: 21-3459 GC
Hon. Tina Brooks Green
PLAINTIFF’S MOTION TO WAIVE SERVICE TO GREGG GERAGOCIAN
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MOTION TO WAIVE SERVICE TO GREGG GERAGOCIAN
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NOW COMES Darryl West, Plaintiff, and brings this Motion to Waive Service to Gregg
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Geragocian, Defendant, and hereby avers as follows:
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1. Plaintiff conferred with the attorney of I-94 Marine & Watersports to ask him if he 21
was representing Gregg Geragocian during the course of these proceedings.
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2. The attorney for I-94 Marine & Watersports, Mr. Jared Andrezejewski informed
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Darryl that he would represent Gregg Geragocian if he was served with his pleadings. The email
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sent by Mr. Andrezejewski is attached.
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3. In that regard, it is tenable to serve Mr. Jared Andrezejewski with pleadings for 27
both Defendants without having to serve Gregg Geragocian.
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PLAINTIFF’S MOTION TO WAIVE SERVICE TO GREGG GERAGOCIAN – 3
4. Plaintiffs would like to serve Mr. Jared Andezejewski with pleadings for Gregg 1
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Geragocian throughout the course of these proceedings.
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REASONS WHEREFORE, Plaintiff respectfully requests this Honorable Court to grant his 4
Motion to Waive Service to Gregg Geragocian.
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Dated this [DATE] day of [MONTH], 2021.
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Respectfully Submitted,
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___________________________________
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Darryl West
Plaintiff in pro per
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PLAINTIFF’S MOTION TO WAIVE SERVICE TO GREGG GERAGOCIAN – 4
VERIFICATION
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I, Darryl West, being duly sworn depose and say that I am the Plaintiff in the above entitled action,
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that I have read the foregoing Motion to Waive Service to Gregg Geragocian and know the contents 4
thereof. That the same is true of my own knowledge except as to those matters and things stated 5
upon information and belief, and as to those things, I believe them to be true. 6
_________________________________
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(Sign in the presence of a Notary Public)
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Sworn to and subscribed before me this _____ day of ____________________, 2021. 10
______________________________
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Notary Public
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________________________________________
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(Printed name of Notary Public)
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My Commission Expires: ____________________
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PLAINTIFF’S MOTION TO WAIVE SERVICE TO GREGG GERAGOCIAN – 5
VERIFICATION
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I, Joseph West, being duly sworn depose and say that I am the Plaintiff in the above entitled action,
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that I have read the foregoing Motion to Waive Service to Gregg Geragocian and know the contents 4
thereof. That the same is true of my own knowledge except as to those matters and things stated 5
upon information and belief, and as to those things, I believe them to be true. 6
_________________________________
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(Sign in the presence of a Notary Public)
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Sworn to and subscribed before me this _____ day of ____________________, 2021. 10
______________________________
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Notary Public
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________________________________________
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(Printed name of Notary Public)
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My Commission Expires: ____________________
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PLAINTIFF’S MOTION TO WAIVE SERVICE TO GREGG GERAGOCIAN – 6
Darryl West
1
5650 Carpenter Road
2
Ypsilanti, MI 48197
(734) 961-2493
3
darrylsfamily2@gmail.com
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Plaintiff in pro per
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IN THE 34TH DISTRICT COURT
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FOR THE COURT OF WAYNE
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DARRYL WEST,
Plaintiff,
vs.
I-94 MARINE & WATERSPORTS, Defendant
Case No.: 21-3459 GC
Hon. Tina Brooks Green
PLAINTIFF’S MOTION TO WAIVE SERVICE TO GREGG GERAGOCIAN
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[PROPOSED] ORDER GRANTING PLAINTIFF’S MOTION TO WAIVE SERVICE TO 18
GREGG GERAGOCIAN
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This Matter, having come before the Court on Plaintiff’s Motion to Waive Service to Gregg 21
Geragocian, and it appearing, upon Plaintiff’s argument and good cause shown, that the Motion 22
should be granted, IT IS HEREBY ORDERED that Plaintiff’s Motion is GRANTED. 23
Entered this ____ day of __________________, 2021.
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___________________________________
Hon. Tina Brooks Green
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PLAINTIFF’S MOTION TO WAIVE SERVICE TO GREGG GERAGOCIAN – 7
CERTIFICATE OF SERVICE
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I hereby certify that a true and correct copy of the foregoing document was sent on the (Date) day 3
of (Month) (Year) by regular U.S. mail, by facsimile, or certified mail, return receipt requested, to 4
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the following parties or attorneys of record:
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Jared J. Andrzejewski, Attorney at Law
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Ogne, Alberts & Stuart, P.C
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1869 East Maple Road
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Troy, MI 48083
(248) 362-3707
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jandrzejewski@oaspc.com
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Dated this [DATE] day of [MONTH], 2021.
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Respectfully Submitted,
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___________________________________
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Darryl West
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Plaintiff in pro per
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PLAINTIFF’S MOTION TO WAIVE SERVICE TO GREGG GERAGOCIAN – 8
Jared Andrzejewski Tue, Sep 7, 8:56 AM (9 days ago)
to Katie, me
Darryl,
If Gregg was served with the original complaint, please forward that proof of service. Please also forward a copy of the motion to strike and/or correct defendant’s amended answer with the notice of hearing. It is my position that Gregg was not properly served with the Amended Complaint and is not a proper party to the lawsuit. As I do not represent him until he is properly served, I cannot file an answer on his behalf. I filed an answer to the amended complaint on behalf of I-94 Marine & Water Sports.
Thank you,
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