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FILED: NEW YORK COUNTY CLERK 04/25/2019 03:45 PM INDEX NO. 650538/2018
NYSCEF DOC. NO. 81 RECEIVED NYSCEF: 04/25/2019
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF NEW YORK
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Index No.650538/2018
DR. JONATHAN A. KORN,
Hon. Melissa A. Crane
Plaintiff, IAS Part 15
-against- AFFIRMATION OF ANDREW T.
SOLOMON IN SUPPORT MOTION
SACCO & FILLAS, LLP.,
FOR SUMMARY JUDGMENT
Defendant.
MOTION SEQ. NO. 006
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ANDREW T. SOLOMON, an attorney admitted to practice before the Courts of the State
of New York, states under penalty of perjury that the following statements are true and correct:
1. I am a partner with the law firm of Solomon & Cramer LLP, counsel to Plaintiff
in this action. I submit this affirmation in support of Plaintiff’s motion for summary judgment
against Sacco & Fillas, LLP (“S&F”).
2. Attached hereto as Exhibits 1 and 2 are the Complaint and Answer in this Action,
e-filed as NYSCEF Docs. 001 and 003.
3. Attached as Exhibit 3 is true copy of an order issued by the Suffolk County
Supreme Court dated March 27, 2017 in the matter of Amandola v. Torres, Index No. 10-1874
(the “PI Suit”).
4. Attached as Exhibit 4 is a true copy of the docket sheet in the PI Suit.
5. Attached as Exhibit 5 is a true copy of a letter, with attachments, from Jason
Krantz, Esq. to Tonino Sacco, Esq. dated July 11, 2011. The letter and its attachments were
produced by S&F, which I numbered as S&F001-004.
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FILED: NEW YORK COUNTY CLERK 04/25/2019 03:45 PM INDEX NO. 650538/2018
NYSCEF DOC. NO. 81 RECEIVED NYSCEF: 04/25/2019
6. Attached as Exhibit 6 is a true copy of a letter from Tonino Sacco, Esq. to Jason
Krantz, Esq. dated July 12, 2011. The letter was produced by S&F, which I numbered as
S&F005.
7. Attached as Exhibit 7 is a true copy of a letter, with its attachment, from Jason
Krantz, Esq. to Tonino Sacco, Esq. dated July 14, 2011 The letter was produced by S&F, which
I numbered as S&F006-007.
8. Attached as Exhibit 8 is a true copy of certain Assignment, Sale, Springing
Assignment & Equitable Lien Agreement, dated as of July 20, 2011, between Joan Amandola
and Singer Asset Finance Company, L.L.C. This agreement was produced by S&F, which I
numbered as S&F008-018.
9. Attached as Exhibit 9 is a true copy of certain Assignment, Sale, Springing
Assignment & Equitable Lien Agreement, dated as of March 22, 2012, between Joan Amandola
and Singer Asset Finance Company, L.L.C. This agreement was produced by S&F as S&F019-
029.
10. Attached as Exhibit 10 is a true copy of a June 15, 2017 check made payable to
“Sacco & Fillas, LLP as Attorneys and Joan Amandola” for $250,000 from Travelers Insurance
Company. This check was produced by S&F, which I numbered as S&F030.
11. Attached as Exhibit 11 is a true copy of a June 26, 2017 check made payable to
“Sacco & Fillas, LLP” for $11,020.17 from IOLA-Sacco & Fillas, LLP. This check was
produced by S&F, which I numbered as S&F031.
12. Attached as Exhibit 12 is a true copy of a July 10, 2017 check made payable to
“Joan McGowan Amandola” for $59,319.89 from IOLA-Sacco & Fillas, LLP. This check was
produced by S&F, which I numbered as S&F032.
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13. Attached as Exhibit 13 is a true copy of a July 10, 2017 check made payable to
“Singer Asset Finance Company” for $100,000 from IOLA-Sacco & Fillas, LLP. This check
was produced by S&F, which I numbered as S&F033.
Dated: New York, New York
April 23, 2019
/s/Andrew T. Solomon
Andrew T. Solomon
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FILED: NEW YORK COUNTY CLERK 04/25/2019 03:45 PM INDEX NO. 650538/2018 NYSCEF DOC. NO. 81 RECEIVED NYSCEF: 04/25/2019 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF NEW YORK -----------------------------------------------------------------------X Index No.650538/2018 DR. JONATHAN A. KORN, Hon. Melissa A. Crane Plaintiff, IAS Part 15 -against- AFFIRMATION OF ANDREW T. SOLOMON IN SUPPORT MOTION SACCO & FILLAS, LLP., FOR SUMMARY JUDGMENT Defendant. MOTION SEQ. NO. 006 -----------------------------------------------------------------------X ANDREW T. SOLOMON, an attorney admitted to practice before the Courts of the State of New York, states under penalty of perjury that the following statements are true and correct: 1. I am a partner with the law firm of Solomon & Cramer LLP, counsel to Plaintiff in this action. I submit this affirmation in support of Plaintiff’s motion for summary judgment against Sacco & Fillas, LLP (“S&F”). 2. Attached hereto as Exhibits 1 and 2 are the Complaint and Answer in this Action, e-filed as NYSCEF Docs. 001 and 003. 3. Attached as Exhibit 3 is true copy of an order issued by the Suffolk County Supreme Court dated March 27, 2017 in the matter of Amandola v. Torres, Index No. 10-1874 (the “PI Suit”). 4. Attached as Exhibit 4 is a true copy of the docket sheet in the PI Suit. 5. Attached as Exhibit 5 is a true copy of a letter, with attachments, from Jason Krantz, Esq. to Tonino Sacco, Esq. dated July 11, 2011. The letter and its attachments were produced by S&F, which I numbered as S&F001-004. 1 of 3 FILED: NEW YORK COUNTY CLERK 04/25/2019 03:45 PM INDEX NO. 650538/2018 NYSCEF DOC. NO. 81 RECEIVED NYSCEF: 04/25/2019 6. Attached as Exhibit 6 is a true copy of a letter from Tonino Sacco, Esq. to Jason Krantz, Esq. dated July 12, 2011. The letter was produced by S&F, which I numbered as S&F005. 7. Attached as Exhibit 7 is a true copy of a letter, with its attachment, from Jason Krantz, Esq. to Tonino Sacco, Esq. dated July 14, 2011 The letter was produced by S&F, which I numbered as S&F006-007. 8. Attached as Exhibit 8 is a true copy of certain Assignment, Sale, Springing Assignment & Equitable Lien Agreement, dated as of July 20, 2011, between Joan Amandola and Singer Asset Finance Company, L.L.C. This agreement was produced by S&F, which I numbered as S&F008-018. 9. Attached as Exhibit 9 is a true copy of certain Assignment, Sale, Springing Assignment & Equitable Lien Agreement, dated as of March 22, 2012, between Joan Amandola and Singer Asset Finance Company, L.L.C. This agreement was produced by S&F as S&F019- 029. 10. Attached as Exhibit 10 is a true copy of a June 15, 2017 check made payable to “Sacco & Fillas, LLP as Attorneys and Joan Amandola” for $250,000 from Travelers Insurance Company. This check was produced by S&F, which I numbered as S&F030. 11. Attached as Exhibit 11 is a true copy of a June 26, 2017 check made payable to “Sacco & Fillas, LLP” for $11,020.17 from IOLA-Sacco & Fillas, LLP. This check was produced by S&F, which I numbered as S&F031. 12. Attached as Exhibit 12 is a true copy of a July 10, 2017 check made payable to “Joan McGowan Amandola” for $59,319.89 from IOLA-Sacco & Fillas, LLP. This check was produced by S&F, which I numbered as S&F032. 2 2 of 3 FILED: NEW YORK COUNTY CLERK 04/25/2019 03:45 PM INDEX NO. 650538/2018 NYSCEF DOC. NO. 81 RECEIVED NYSCEF: 04/25/2019 13. Attached as Exhibit 13 is a true copy of a July 10, 2017 check made payable to “Singer Asset Finance Company” for $100,000 from IOLA-Sacco & Fillas, LLP. This check was produced by S&F, which I numbered as S&F033. Dated: New York, New York April 23, 2019 /s/Andrew T. Solomon Andrew T. Solomon 3 3 of 3