MOTION TO DISMISS COMPLAINT FOR FAILURE TO MAKE DISCOVERY submitted by MONTAG, DAVID, JASON of MILBER MAKRIS PLOUSADIS & SEIDEN, LLP on behalf of CBRE MANAGEMENT GROUP against OLSI SHKEMBI AND, DESHIRA SHKEMBI, HIS WIFE *LINKED FILING*

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On October 18, 2022 a case was filed by Cbre Management Group, Deshira Shkembi, and Olsi Shkembi, represented by Thomas A Zammatore, and Walter A Lesnevich, against Abc Corporations 1-5, Cbre Management Group, John Does 1-5, New Jersey Urology Llc, and Park 80 East, Llc, represented by David Jason Montag, Renada Michelle Williams, and Renee Catherine Rivas, in the jurisdiction of Bergen County. Judge Gregg A Padovano presiding.

                        
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                                BER-L-005611-22 09/06/2023 12:44:07 PM Pg 1 of 2 Trans ID: LCV20232531630




David J. Montag, Esq., Attorney ID # 027351997
MILBER MAKRIS PLOUSADIS
  & SEIDEN, LLP
75 Livingston Avenue, Suite 103
Roseland, New Jersey 07068
 (201) 433-0778
Attorneys for Defendant, CBRE Inc., incorrectly pled as CBRE Management Group
File No.: 0489NJ-24533

OLSI SHKEMBI and DESHIRA SHKMEBI,                SUPERIOR COURT OF NEW JERSEY
his wife,                                        LAW DIVISION: BERGEN COUNTY

                 Plaintiffs,                     Docket No. BER-L-5611-22
-against-
                                                                    Civil Action
CBRE MANAGEMENT GROUP, JOHN
DOES 1-5; ABC CORPORATIONS 1-5; and
NEW JERSEY UROLOGY LLC,                            NOTICE OF MOTION TO STRIKE
                                                     PLAINTIFF’S COMPLAINT
                Defendants.                            WITHOUT PREJUDICE



TO:    ALL COUNSEL OF RECORD

DATE RE…