Omnibus Motion 1(a)

PLEASE TAKE NOTICE, that Respondent, the undersigned (respondent) will

move this Court at a Motion term held before Part O at the New York County (Civil)

Courthouse located at 111 Centre Street, on the 29th day of June, 2006 at 9:30 A.M., or as soon

thereafter as practicable, for an order:

1. Granting Jury Trial for pending MOTION TO DISMISS WITH PREJUDICE for improper jurisdiction.

2. Granting Jury Trial for pending MOTION TO DISMISS WITH PREJUDICE for improper standing.

CPLR §2218. Trial of issue raised on motion. The court may order that an issue of fact raised on a motion shall be separately tried by the court or a referee. If the issue is triable of right by jury, the court shall give the parties an opportunity to demand a jury trial of such issue. Failure to make such demand within the time limited by the court, or, if no such time is limited, before trial begins, shall be deemed a waiver of the right to trial by jury. An order under this rule shall specify the issue to be tried.

and all such and further relief that this court may deem just and proper.