First MOTION to Dismiss for Failure to State a Claim by CROSS RIVER BANK.… — Recap Pull 2026 06 12 (Dkt. 21)

Summary

A notice of motion to dismiss for failure to state a claim filed by defendant Cross River Bank in Docket No. 2:21-cv-15146-KM-ESK in the U.S. District Court for the District of New Jersey, dated October 4, 2021 and filed as Doc. 21. The notice states that on November 1, 2021, or another date set by the court, the bank will move before Judge Kevin McNulty for an order dismissing the complaint in its entirety under Fed. R. Civ. P. 12(b)(6). It states that the motion relies on a brief and a certification of defense counsel Jennifer Casazza Carter, that a proposed form of order is submitted, and that the defendant requests oral argument. The one-page notice is signed by Iram P. Valentin of Kaufman Dolowich & Voluck, LLP, attorneys for Cross River Bank.

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 Case 2:21-cv-15146-KM-ESK Document 21 Filed 10/04/21 Page 1 of 1 PageID: 73




                             UNITED STATES DISTRICT COURT
                                DISTRICT OF NEW JERSEY

HARBORVIEW CPITAL PARTNERS, LLC,                       Docket No. 2:21-cv-15146-KM-ESK

                Plaintiff,                          NOTICE OF MOION TO DISMISS FOR
                                                       FAILURE TO STATE A CLAIM
  v.                                                PURSUANT TO FED. R. CIV. P. 12(b)(6)

CROSS RIVER BANK,                                         Return Date: November 1, 2021

               Defendant.                              ORAL ARGUMENT REQUESTED

       PLEASE TAKE NOTICE that on November 1, 2021, or such other date as set by the

Court, Defendant Cross River Bank, by and through its counsel, Kaufman Dolowich & Voluck,

LLP, will move before the Honorable Kevin McNulty, U.S.D.J., Martin Luther King Building &

U.S. Courthouse, 50 Walnut Street, Newark, New Jersey, for entry of an Order dismissing the

Complaint in its entirety for failure to state a claim, pursuant to Fed. R. Civ. P. 12(b)(6).

       PLEASE TAKE FURTTHER NOTICE, that in support of their motion, Defendant will

rely upon the Brief and Certification of Jennifer Casazza Carter, Esq. submitted herewith. A

proposed form of Order is also submitted herewith.

       PLEASE TAKE FURTHER NOTICE that Defendant respectfully requests oral

argument.

                                       KAUFMAN DOLOWICH VOLUCK, LLP

                                       BY:     /s/Iram P. Valentin, Esq.
                                               Iram P. Valentin, Esq.
                                               Jennifer Casazza Carter, Esq.
                                               Court Plaza North
                                               25 Main Street, Suite 500
                                               Hackensack, New Jersey 07601
                                               (T): (201) 488-6655
                                               Ivalentin@kdvlaw.com
                                               jcasazza@kdvlaw.com
                                               Attorneys for Defendant, Cross River Bank
Dated: October 4, 2021


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