On August 27, 2009 a
Motion-Secondary
was filed
involving a dispute between
Deutsche Bank National Trust Company As Trustee For American Home Mortgage Assets Trust 2007-1 Mortgage-Backed Pass-Through Certificates, Series 2007-1,
and
City Of New York Environmental Control Board,
City Of New York Parking Violations Bureau,
John Doe #1 Through John Doe #10,,
New York City,
Ny State Department Of Taxation And Finance,
Royal Blue Realty Holdings, Inc.,
Sing Yu International, Inc. D B A Sy Marble And Granite Importers And Distributors,
State Of New York,
The Board Of Managers Of 130 Barrow Street Condominium Homeowners Association,
The Last Ten Names Being Fictitious And Unknown To The Plaintiff, The Person Or Parties Intended Being The Person Or Parties, If Any, Having Or Claiming An Interest In Or Lien Upon The Mortgaged Premises Described In The Complaint,,
for Torts - Other (Conversion)
in the District Court of New York County.
Preview
FILED: NEW YORK COUNTY CLERK 02/07/2020 04:19 PM INDEX NO. 107030/2009
NYSCEF DOC. NO. 213 RECEIVED NYSCEF: 02/07/2020
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF NEW YORK
DEUTSCHE BANK NATIONAL TRUST Index No. 107028/09; 107029/09;
COMPANY, 107030/09; 107017/09; 107031/09;
110570/10; 850071/16; 105818/09;
Plaintiff, 105819/09
Hon. Arlene Bluth
-against-
AFFIRMATION OF JAMIE C.
ROYAL BLUE REALTY HOLDINGS, INC., ET AL., KRAPF, ESQ. IN SUPPORT OF
PLAINTIFF'S
Defendants. MOTION TO DISQUALIFY
MARTIN SHAW
JAMIE C. KRAPF, an attorney duly admitted to practice law in the State of New York,
hereby affirms under penalty of perjury as follows:
1. I am a member of the New York State Bar and am associated with McCabe,
Weisberg & Conway, LLC, co-counsel for Plaintiff ("Plaintiff"). I am fully familiar with the
facts and circumstances set forth herein.
2. I submit this affirmation in support of Plaintiff's motion to disqualify Martin
Shaw, Esq. ("Shaw") from representing Defendant Royal Blue Realty Holdings, Inc.
("Defendants"
or "Royal Blue") in nine related actions, pursuant to Rules 3.7, 1.7, and 1.9 of the
New York Rules of Professional Conduct ("RPC"), 22 NYCRR Part 1200.
3. At a court conference held on March 21, 2019, whereat the issue of Royal Blue
and Shaw's inability to produce any materially relevant documents in response to document
demands and a subpoena served on them, Shaw, at a side bar conference, stated that he ceased
representing Royal Blue in connection with the subject condominium conversion and offering
plan no later than 2003-2004 and did not resume representing Royal Blue until after the
foreclosure actions had been commenced. The attached documents demonstrate that this
statement is untrue.
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FILED: NEW YORK COUNTY CLERK 02/07/2020 04:19 PM INDEX NO. 107030/2009
NYSCEF DOC. NO. 213 RECEIVED NYSCEF: 02/07/2020
Dated: New Rochelle, New York
February 4, 2020
McCABE, WEISBERG & CONWAY, LLC
amie C. Krapf
1 5 Hu uenot Street, Ste. 210
Tew achelle, New York 10801
el: 31) 812-4084
Cc - ounsel for Plaintiff
2 of 2
Document Filed Date
February 07, 2020
Case Filing Date
August 27, 2009
Category
Torts - Other (Conversion)
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