Preview
FILED: KINGS COUNTY CLERK 05/07/2024 11:31 PM INDEX NO. 507184/2022
NYSCEF DOC. NO. 209 RECEIVED NYSCEF: 05/07/2024
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF KINGS
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NAWSHAD BEDESSEE and INVOR BEDESSEE, Index No. 507184/2022
Plaintiffs, Motion Seq. No. 008
-against- AFFIRMATION OF
VERMAN BEDESSEE
VERMAN BEDESSEE, RAYMAN BEDESSEE, IN OPPOSITION TO
BEDESSEE IMPORTS INC., ANDREW MOTION AND IN SUPPORT
BEDESSEE CORP., BEDESSEE HOLDINGS INC., OF CROSS MOTION
BEDESSEE EAST-WEST INDIAN FOOD, INC.
D/B/A BEDESSEE SPORTING GOODS, and
OTHER XYZ COPRORATIONS 1-10, the true
names of which are unknown to the Plaintiff,
Defendants.
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VERMAN BEDESSEE, hereby affirms pursuant to CPLR 2106, as more fully set
forth below:
1. I am the president, sole shareholder and director of Bedessee Imports Inc. a
corporation organized and existing under the laws of the State of New York (hereinafter sometimes
referred to as “BINY”). I have held the position of president since around or about the time that my
father and company founder Lionel Bedessee passed away in March 2017. Prior to serving as
President I held the position of Vice President since around or about the incorporation of BINY in
1985. I also worked for Lionel Bedessee’s proprietorship that was the predecessor to BINY, prior
to its incorporation. As such I am fully familiar with the facts and circumstances set forth below.
2. I make this affirmation in opposition to the Plaintiffs’ motion to compel the
Moving Defendants’ attorney, Samuel Friedman, Esq., to comply with the subpoena duces tecum
and ad testficandum; and in support of the Moving Defendants’ Cross Motion pursuant to CPLR
2304 to quash the subpoena and pursuant to CPLR 3103(a) for a protective order relieving Samuel
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Friedman, Esq. from having to respond to the subpoena.
3. BINY is the exclusive licensee of around or about twenty United States
Trademark Registrations owned by Bedessee Imports Ltd. (hereinafter sometimes referred to as
“BIC”), which is our sister company in Ontario, Canada. Samuel Friedman, Esq. has been the U.S.
trademark lawyer used by both Bedessee Imports Ltd. and Bedessee Imports Inc. since around or
about 2006. Samuel Friedman has also represented BIC and BINY in connection with several
trademark, trademark litigation, commercial litigation and other legal matters over the years.
4. I have reviewed the Affirmation in Support of Motion to Compel submitted
by Invor Bedessee (“Invor”) dated April 11, 2024; as well as the Affirmation in Support of Motion
to Compel submitted by Nawshad Bedessee (“Nawshad”) dated April 15, 2024. Both affirmations
contain many false statements.
5. I never attended any in person meetings that included Invor and Samuel
Friedman.
6. I never attended any in person meetings that included Nawshad, Invor and
Samuel Friedman.
7. Over the years, I have attended several in person meetings that included
Rayman Bedessee (“Rayman”) and Samuel Friedman. Neither Nawshad nor Invor were present
during any of these meetings with Samuel Friedman and Rayman.
8. I have also had many telephone conversations with Samuel Friedman
concerning trademark applications, prosecutions, post-registration maintenance, trademark
litigation, regulatory compliance, contracts and commercial litigation, including but not limited to
the instant litigation. Rayman also participated in many of these telephone conversations with
Samuel Friedman.
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9. All of my conversations, meetings and communications with Samuel
Friedman were solely for the purpose of obtaining legal advice.
10. To the best of my knowledge, Invor never served as a corporate director of
BINY or Bedessee Holdings Inc. or Andrew Bedessee Corp. (sometimes collectively referred to as
the “Bedessee companies in New York”). Invor may, at some point, have been held out as having
the title of vice president of BINY, but he never had any duties or responsibilities for BINY or any
of the Bedessee companies in New York.
11. To the best of my knowledge, Invor has never participated in any bank loans,
refinance of bank loans, or banking agreements for BIC, BINY or any of the Bedessee companies in
New York, except perhaps for occasionally signing documents that may have been required at
closing.
12. Samuel Friedman did not participate in any meetings of shareholders,
officers or directors of BINY, BIC or any of the Bedessee companies in New York.
13. Samuel Friedman never prepared, wrote or revised any minutes of meetings,
resolutions or registers of shareholders, officers or directors of BINY, BIC or any of the Bedessee
companies in New York.
14. Samuel Friedman did not keep the corporate books and records of BINY,
BIC or any of the Bedessee companies in New York.
15. Nawshad does not and did not serve as a corporate director of BINY or
Bedessee Holdings Inc. or Andrew Bedessee Corp. However, Nawshad did serve as a Vice
President of BINY.
16. Nawshad has his own, separate company known as Bedessee East-West
Indian Food, Inc. d/b/a Bedessee Sporting Goods (“BSG”). Nawshad holds himself out as the
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president and sole shareholder of BSG. Nawshad has, in the past, performed some duties for BINY.
In return, Nawshad was given access to the BINY warehouse, a salary and some benefits. But
Nawshad failed to perform his duties for BINY. Consequently, I terminated his salary from BINY
and I attempted to terminate his benefits.
17. It is possible that Nawshad has held himself out as a director of BINY and
the other Bedessee companies in New York. The business has not operated following traditional
formalities. It is possible that there are documents that indicate that Nawshad was a director.
However, this was not done in any formal sense. Nawshad does not and did not participate in high
level management. To the extent that one might argue that Nawshad is or was previously a director
of BINY or the Bedessee companies in New York, Nawshad is nothing more than a faithless
director. Nawshad has breached his fiduciary duties to the company.
18. As more fully set forth in Defendant’s Answer to Amended Complaint and
Amended Counterclaims [NYSCEF # 182] (Counterclaim Pars. 1-94; Pages 9-23) it has come to
our attention that since at least as early as 2020, Nawshad has been breaching his fiduciary duties to
BINY, BIC and the Bedessee companies in New York (collectively “Bedessee”). Nawshad has
been stealing Bedessee products, infringing our trademarks, conspiring with Bedessee competitors,
competing unfairly with Bedessee while using Bedessee resources, suppliers, and confidential
information for his own personal gain. Nawshad has intentionally damaged Bedessee by locking us
out of our FDA account and otherwise interfered with our regulatory compliance. He has failed to
pay rent for the space that his separate company, Bedessee East-West Indian Food, Inc. d/b/a
Bedessee Sporting Goods occupies at 601 Wortman Avenue, Brooklyn, New York.
19. Moreover, Nawshad and Invor are currently litigating against BIC, Rayman
and me in Canada. Nawshad and Invor have otherwise worked in manners inimical to Bedessee.
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20. Samuel Friedman was not the legal representative of BINY, BIC or any of
the Bedessee companies in New York in the purchase, finance or refinance of any real estate.
Samuel Friedman was not the legal representative of BINY, BIC or any of the of the Bedessee
companies in New York for any applications for financing, loans or lines of credit.
21. The lawyer used by BINY and the Bedessee Companies in New York for the
purpose of incorporating Bedessee Holdings Inc. and in connection with financing and real estate
closings is Samuel B. Freed, Esq. Although Samuel B. Freed, Esq. and Samuel Friedman, Esq.
have similar names, they are not the same person. To the best of my knowledge they have
completely separate law practices. Samuel B. Freed is the lawyer that was used by the Bedessee
companies in New York in or about 2000 for the purchase of 601 Wortman Avenue as well as the
incorporation of Bedessee Holdings Inc. and Andrew Bedessee Corp. Similarly, Samuel B. Freed,
Esq. is the lawyer used by the Bedessee companies in New York for all of the refinancings of 601
Wortman Avenue, Brooklyn , New York, as well as in obtaining any bank loans or lines of credit.
22. In or about 2010 we did a bank refinancing for the real estate at 601
Wortman Avenue, Brooklyn, New York. The lawyer that the Bedessee companies used for the
refinancing, which was with Flushing Savings Bank, was Samuel B. Freed. Our trademark lawyer,
Samuel Friedman, was not involved in the Flushing Savings Bank refinancing.
23. In or about 2018, we did another refinance of the 601 Wortman Avenue real
estate. We again used Samuel B. Freed as our lawyer for the refinance. Our trademark and
litigation attorney, Samuel Friedman, was not involved in the refinance with Chase Bank. I have
attached an email sent on April 4, 2017 from my brother Nawshad Bedessee which demonstrates
that Nawshad was well aware that we were seeking to refinance the mortgage on the 601 Wortman
Avenue real estate. A true copy of that email is annexed as Exhibit H.
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24. Thereafter, our business was deteriorating due to, among other things, a lack
of coordination between the different members of the extended Bedessee family that were working
in the Bedessee companies in New York, and our sales were decreasing.
25. On or about February 19, 2018 I sent an email to Samuel Friedman, Esq.,
Samuel Freed, Esq., Rayman, Nawshad, Invor and Andrew Bedessee, advising of the imminent
refinance with Chase Bank, and asking Samuel Friedman, Esq. to tell Samuel Freed, Esq. if there
are any open cases against the Bedessee companies in New York. A true copy thereof is annexed as
Exhibit I.
26. On or about August 5, 2019, I sent an email to Samuel B. Freed, my brothers
Rayman Bedessee, Nawshad Bedessee and Invor Bedessee as well as other members of the
Bedessee family and key employees explaining that we were in desperate financial conditions and
needed to increase our sales and productivity. In that email I explained to “everyone that Samuel
Freed is the company business attorney. We also have Samuel Friedman with similar name who is
the company Trademark attorney.” A true copy of that email is annexed hereto as Exhibit J.
27. The Bedessee companies in New York were in dire financial straits, and
therefore we sought a further refinance which was necessary because Chase bank did not agree to
extend our line of credit. Accordingly, I had the task of finding additional financing to keep our
New York business operational. On or about December 24, 2020 the New York Bedessee
companies did an additional refinance of our mortgage with Dime Bank. As before, our attorney for
the real estate transaction refinancing was Samuel B. Freed. Our trademark and litigation attorney,
Samuel Friedman, was not involved in the refinancing with Dime Bank or obtaining lines of credit
from Dime Bank.
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28. The closing files for all of the above referenced real estate transactions and
refinancings have been or will be produced during discovery in this litigation.
29. In or about 2020 I participated in a few telephone conversations that
included Nawshad, Invor, Rayman, several other members of the Bedessee family and Samuel
Friedman. The purpose of these telephone conversations was to try to reach a compromise solution
to the disagreements that had developed primarily between Nawshad and me regarding the
operation of the Bedessee companies in New York, as well as Nawshad’s separate company BSG.
Our efforts to reach a compromise solution were unsuccessful.
30. We also openly discussed the fact that the Bedessee companies in New York
were applying to refinance the mortgage and obtain lines of credit secured by the real estate at 601
Wortman Avenue, Brooklyn, New York, as well as my own personal guaranty. Just before a
conference call of December 3, 2020 I sent an email to Nawshad, Invor, Rayman, my son Andrew
and Samuel Friedman, annexed as Exhibit K, in which I made clear that I was refinancing the
mortgage on 601 Wortman Avenue due to financial necessity resulting from lack of sales. Nawshad
and Invor were fully informed of the refinance of the mortgage and obtaining lines credit. Their
statements to the contrary are false.
[INTENTIONALLY LEFT BLANK]
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WHEREFORE, it is respectfully requested that this Court deny the Plaintiffs'
motion to compel in in its entirety, grant the cross motion to quash and for a protective order; and
award such other, further and different relief as this Court deems just and proper under the
circumstances.
VERMAN BEDESSEE affirms, this 7th day of May, 2024, under the penalties of
perjury under the laws ofNew York, which may include a fme or imprisonment, that the foregoing
is true, and I understand that this document may be filed in an action or proceeding in a court of law.
L
VERMAN BEDESSEE
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Preview
FILED: KINGS COUNTY CLERK 05/07/2024 11:31 PM INDEX NO. 507184/2022 NYSCEF DOC. NO. 209 RECEIVED NYSCEF: 05/07/2024 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF KINGS --------------------------------------------------------------------x NAWSHAD BEDESSEE and INVOR BEDESSEE, Index No. 507184/2022 Plaintiffs, Motion Seq. No. 008 -against- AFFIRMATION OF VERMAN BEDESSEE VERMAN BEDESSEE, RAYMAN BEDESSEE, IN OPPOSITION TO BEDESSEE IMPORTS INC., ANDREW MOTION AND IN SUPPORT BEDESSEE CORP., BEDESSEE HOLDINGS INC., OF CROSS MOTION BEDESSEE EAST-WEST INDIAN FOOD, INC. D/B/A BEDESSEE SPORTING GOODS, and OTHER XYZ COPRORATIONS 1-10, the true names of which are unknown to the Plaintiff, Defendants. --------------------------------------------------------------------x VERMAN BEDESSEE, hereby affirms pursuant to CPLR 2106, as more fully set forth below: 1. I am the president, sole shareholder and director of Bedessee Imports Inc. a corporation organized and existing under the laws of the State of New York (hereinafter sometimes referred to as “BINY”). I have held the position of president since around or about the time that my father and company founder Lionel Bedessee passed away in March 2017. Prior to serving as President I held the position of Vice President since around or about the incorporation of BINY in 1985. I also worked for Lionel Bedessee’s proprietorship that was the predecessor to BINY, prior to its incorporation. As such I am fully familiar with the facts and circumstances set forth below. 2. I make this affirmation in opposition to the Plaintiffs’ motion to compel the Moving Defendants’ attorney, Samuel Friedman, Esq., to comply with the subpoena duces tecum and ad testficandum; and in support of the Moving Defendants’ Cross Motion pursuant to CPLR 2304 to quash the subpoena and pursuant to CPLR 3103(a) for a protective order relieving Samuel 1 of 8 FILED: KINGS COUNTY CLERK 05/07/2024 11:31 PM INDEX NO. 507184/2022 NYSCEF DOC. NO. 209 RECEIVED NYSCEF: 05/07/2024 Friedman, Esq. from having to respond to the subpoena. 3. BINY is the exclusive licensee of around or about twenty United States Trademark Registrations owned by Bedessee Imports Ltd. (hereinafter sometimes referred to as “BIC”), which is our sister company in Ontario, Canada. Samuel Friedman, Esq. has been the U.S. trademark lawyer used by both Bedessee Imports Ltd. and Bedessee Imports Inc. since around or about 2006. Samuel Friedman has also represented BIC and BINY in connection with several trademark, trademark litigation, commercial litigation and other legal matters over the years. 4. I have reviewed the Affirmation in Support of Motion to Compel submitted by Invor Bedessee (“Invor”) dated April 11, 2024; as well as the Affirmation in Support of Motion to Compel submitted by Nawshad Bedessee (“Nawshad”) dated April 15, 2024. Both affirmations contain many false statements. 5. I never attended any in person meetings that included Invor and Samuel Friedman. 6. I never attended any in person meetings that included Nawshad, Invor and Samuel Friedman. 7. Over the years, I have attended several in person meetings that included Rayman Bedessee (“Rayman”) and Samuel Friedman. Neither Nawshad nor Invor were present during any of these meetings with Samuel Friedman and Rayman. 8. I have also had many telephone conversations with Samuel Friedman concerning trademark applications, prosecutions, post-registration maintenance, trademark litigation, regulatory compliance, contracts and commercial litigation, including but not limited to the instant litigation. Rayman also participated in many of these telephone conversations with Samuel Friedman. 2 2 of 8 FILED: KINGS COUNTY CLERK 05/07/2024 11:31 PM INDEX NO. 507184/2022 NYSCEF DOC. NO. 209 RECEIVED NYSCEF: 05/07/2024 9. All of my conversations, meetings and communications with Samuel Friedman were solely for the purpose of obtaining legal advice. 10. To the best of my knowledge, Invor never served as a corporate director of BINY or Bedessee Holdings Inc. or Andrew Bedessee Corp. (sometimes collectively referred to as the “Bedessee companies in New York”). Invor may, at some point, have been held out as having the title of vice president of BINY, but he never had any duties or responsibilities for BINY or any of the Bedessee companies in New York. 11. To the best of my knowledge, Invor has never participated in any bank loans, refinance of bank loans, or banking agreements for BIC, BINY or any of the Bedessee companies in New York, except perhaps for occasionally signing documents that may have been required at closing. 12. Samuel Friedman did not participate in any meetings of shareholders, officers or directors of BINY, BIC or any of the Bedessee companies in New York. 13. Samuel Friedman never prepared, wrote or revised any minutes of meetings, resolutions or registers of shareholders, officers or directors of BINY, BIC or any of the Bedessee companies in New York. 14. Samuel Friedman did not keep the corporate books and records of BINY, BIC or any of the Bedessee companies in New York. 15. Nawshad does not and did not serve as a corporate director of BINY or Bedessee Holdings Inc. or Andrew Bedessee Corp. However, Nawshad did serve as a Vice President of BINY. 16. Nawshad has his own, separate company known as Bedessee East-West Indian Food, Inc. d/b/a Bedessee Sporting Goods (“BSG”). Nawshad holds himself out as the 3 3 of 8 FILED: KINGS COUNTY CLERK 05/07/2024 11:31 PM INDEX NO. 507184/2022 NYSCEF DOC. NO. 209 RECEIVED NYSCEF: 05/07/2024 president and sole shareholder of BSG. Nawshad has, in the past, performed some duties for BINY. In return, Nawshad was given access to the BINY warehouse, a salary and some benefits. But Nawshad failed to perform his duties for BINY. Consequently, I terminated his salary from BINY and I attempted to terminate his benefits. 17. It is possible that Nawshad has held himself out as a director of BINY and the other Bedessee companies in New York. The business has not operated following traditional formalities. It is possible that there are documents that indicate that Nawshad was a director. However, this was not done in any formal sense. Nawshad does not and did not participate in high level management. To the extent that one might argue that Nawshad is or was previously a director of BINY or the Bedessee companies in New York, Nawshad is nothing more than a faithless director. Nawshad has breached his fiduciary duties to the company. 18. As more fully set forth in Defendant’s Answer to Amended Complaint and Amended Counterclaims [NYSCEF # 182] (Counterclaim Pars. 1-94; Pages 9-23) it has come to our attention that since at least as early as 2020, Nawshad has been breaching his fiduciary duties to BINY, BIC and the Bedessee companies in New York (collectively “Bedessee”). Nawshad has been stealing Bedessee products, infringing our trademarks, conspiring with Bedessee competitors, competing unfairly with Bedessee while using Bedessee resources, suppliers, and confidential information for his own personal gain. Nawshad has intentionally damaged Bedessee by locking us out of our FDA account and otherwise interfered with our regulatory compliance. He has failed to pay rent for the space that his separate company, Bedessee East-West Indian Food, Inc. d/b/a Bedessee Sporting Goods occupies at 601 Wortman Avenue, Brooklyn, New York. 19. Moreover, Nawshad and Invor are currently litigating against BIC, Rayman and me in Canada. Nawshad and Invor have otherwise worked in manners inimical to Bedessee. 4 4 of 8 FILED: KINGS COUNTY CLERK 05/07/2024 11:31 PM INDEX NO. 507184/2022 NYSCEF DOC. NO. 209 RECEIVED NYSCEF: 05/07/2024 20. Samuel Friedman was not the legal representative of BINY, BIC or any of the Bedessee companies in New York in the purchase, finance or refinance of any real estate. Samuel Friedman was not the legal representative of BINY, BIC or any of the of the Bedessee companies in New York for any applications for financing, loans or lines of credit. 21. The lawyer used by BINY and the Bedessee Companies in New York for the purpose of incorporating Bedessee Holdings Inc. and in connection with financing and real estate closings is Samuel B. Freed, Esq. Although Samuel B. Freed, Esq. and Samuel Friedman, Esq. have similar names, they are not the same person. To the best of my knowledge they have completely separate law practices. Samuel B. Freed is the lawyer that was used by the Bedessee companies in New York in or about 2000 for the purchase of 601 Wortman Avenue as well as the incorporation of Bedessee Holdings Inc. and Andrew Bedessee Corp. Similarly, Samuel B. Freed, Esq. is the lawyer used by the Bedessee companies in New York for all of the refinancings of 601 Wortman Avenue, Brooklyn , New York, as well as in obtaining any bank loans or lines of credit. 22. In or about 2010 we did a bank refinancing for the real estate at 601 Wortman Avenue, Brooklyn, New York. The lawyer that the Bedessee companies used for the refinancing, which was with Flushing Savings Bank, was Samuel B. Freed. Our trademark lawyer, Samuel Friedman, was not involved in the Flushing Savings Bank refinancing. 23. In or about 2018, we did another refinance of the 601 Wortman Avenue real estate. We again used Samuel B. Freed as our lawyer for the refinance. Our trademark and litigation attorney, Samuel Friedman, was not involved in the refinance with Chase Bank. I have attached an email sent on April 4, 2017 from my brother Nawshad Bedessee which demonstrates that Nawshad was well aware that we were seeking to refinance the mortgage on the 601 Wortman Avenue real estate. A true copy of that email is annexed as Exhibit H. 5 5 of 8 FILED: KINGS COUNTY CLERK 05/07/2024 11:31 PM INDEX NO. 507184/2022 NYSCEF DOC. NO. 209 RECEIVED NYSCEF: 05/07/2024 24. Thereafter, our business was deteriorating due to, among other things, a lack of coordination between the different members of the extended Bedessee family that were working in the Bedessee companies in New York, and our sales were decreasing. 25. On or about February 19, 2018 I sent an email to Samuel Friedman, Esq., Samuel Freed, Esq., Rayman, Nawshad, Invor and Andrew Bedessee, advising of the imminent refinance with Chase Bank, and asking Samuel Friedman, Esq. to tell Samuel Freed, Esq. if there are any open cases against the Bedessee companies in New York. A true copy thereof is annexed as Exhibit I. 26. On or about August 5, 2019, I sent an email to Samuel B. Freed, my brothers Rayman Bedessee, Nawshad Bedessee and Invor Bedessee as well as other members of the Bedessee family and key employees explaining that we were in desperate financial conditions and needed to increase our sales and productivity. In that email I explained to “everyone that Samuel Freed is the company business attorney. We also have Samuel Friedman with similar name who is the company Trademark attorney.” A true copy of that email is annexed hereto as Exhibit J. 27. The Bedessee companies in New York were in dire financial straits, and therefore we sought a further refinance which was necessary because Chase bank did not agree to extend our line of credit. Accordingly, I had the task of finding additional financing to keep our New York business operational. On or about December 24, 2020 the New York Bedessee companies did an additional refinance of our mortgage with Dime Bank. As before, our attorney for the real estate transaction refinancing was Samuel B. Freed. Our trademark and litigation attorney, Samuel Friedman, was not involved in the refinancing with Dime Bank or obtaining lines of credit from Dime Bank. 6 6 of 8 FILED: KINGS COUNTY CLERK 05/07/2024 11:31 PM INDEX NO. 507184/2022 NYSCEF DOC. NO. 209 RECEIVED NYSCEF: 05/07/2024 28. The closing files for all of the above referenced real estate transactions and refinancings have been or will be produced during discovery in this litigation. 29. In or about 2020 I participated in a few telephone conversations that included Nawshad, Invor, Rayman, several other members of the Bedessee family and Samuel Friedman. The purpose of these telephone conversations was to try to reach a compromise solution to the disagreements that had developed primarily between Nawshad and me regarding the operation of the Bedessee companies in New York, as well as Nawshad’s separate company BSG. Our efforts to reach a compromise solution were unsuccessful. 30. We also openly discussed the fact that the Bedessee companies in New York were applying to refinance the mortgage and obtain lines of credit secured by the real estate at 601 Wortman Avenue, Brooklyn, New York, as well as my own personal guaranty. Just before a conference call of December 3, 2020 I sent an email to Nawshad, Invor, Rayman, my son Andrew and Samuel Friedman, annexed as Exhibit K, in which I made clear that I was refinancing the mortgage on 601 Wortman Avenue due to financial necessity resulting from lack of sales. Nawshad and Invor were fully informed of the refinance of the mortgage and obtaining lines credit. Their statements to the contrary are false. [INTENTIONALLY LEFT BLANK] 7 7 of 8 FILED: KINGS COUNTY CLERK 05/07/2024 11:31 PM INDEX NO. 507184/2022 NYSCEF DOC. NO. 209 RECEIVED NYSCEF: 05/07/2024 WHEREFORE, it is respectfully requested that this Court deny the Plaintiffs' motion to compel in in its entirety, grant the cross motion to quash and for a protective order; and award such other, further and different relief as this Court deems just and proper under the circumstances. VERMAN BEDESSEE affirms, this 7th day of May, 2024, under the penalties of perjury under the laws ofNew York, which may include a fme or imprisonment, that the foregoing is true, and I understand that this document may be filed in an action or proceeding in a court of law. L VERMAN BEDESSEE 8 8 of 8