Preview
(FILED: NASSAU COUNTY CLERK B1/20/2022 01:41 PM _ INDEX NO. 615766/2021
NYSCEF DOC. NO. Me oe RECEIVED NYSCEF: 01/14/2022
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF NASSAU
eecennenene’ (eennewnnscnennceenesnnnmananncen, xX
PEOPLE OF THE STATE OF NEW YORK, by
LETITIA JAMES, Attorney General of the State s ORD
of New York,
i Petitioners, Index No.: 615766/2021
+ against -
| Assigned Justice:
5 CORNERS PET, INC.,, RISK ENTERPRISES, INC. d/b/a HON..HELEN VOUTSINAS
SHAKE+A-PAW, and GERARD O’SULLIVAN and: MARC
JACOBS, both individually and as.owners.of Shake-A-Paw,
Respondents,
aevenneenepnnnnnnmnnncnnnnncceaumeeunvennnnannnnncanennnnnnnewntrammanatimentone K
IT IS HEREBY STIPULATED AND AGREED, by .and between. the
undersigned, the attorneys of record for all the parties to.the above-entitled action, that SMB
G P), is approved by: Petitioners as the independent
veterinarian pursuant to the Order to Show Cause in‘this proceeding dated December 17, 2021,
and-the:cost of his services shall be paid exclusively by Respondents,
¥T IS FURTHER STIPULATED. AND AGREED, (1) Dr. SRQRMMMMEER shall
provide to Petitioners copies of all fit and unfit for sale health certificates issued by him in
connection with his examiriations; (2) Respondents shall provide to Drammen for his review
any medical and medication treatment records and transport records that he requests; (3) Dr.
hall. examine all. puppies on the floor (not in isolation area) or on deposit that have
not already been cleared by Petitioners’ veterinarians, with priority to puppies on deposit; (4) Dr.
may conduct each examination in the manner he deems appropriate in his professional
opinion and he is permitted to. bring an assistant-of his choosing to-assist with his examinations;
and (5): Deal shall provide copies of notes taken. during the.éxaminations to all parties,
including the fit and unfit for-sale health certificates; (6) Dr SERRE shall be permitted to do
random walk-throughs and-conduct examinations where he deems appropriate at both Lynbrook
and Hicksville locations without prior notice to both parties; (7) Dr. MEE and/or his
assistant shall be permitted°to retrieve puppies thernselves from their enclosures, pens, and/or
crates without interference from Respondents, Respondents’ employees, designees, agents and/or
representatives; and (8) Dr. Qll—E@ will be permitted to obtain any samples from the
dogs and/or perform x-rays, and order lab work to be performed:on saniples collected,
should he find them necessary;
E
i
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1 of 2INDEX NO. 615766/2021
RECEIVED NYSCEF: 01/14/2022
(FILED: NASSAU COUNTY CLERK BL/ze 2822 01:41 PM
NYSCEF DOG. NO. 116
11T IS FURTHER STIPULATED AND AGREED, that this stipulation may be
executed in separate counterparts, which together shall constitute the entirety of the Agreement.
Delivery ofa signed:counterpart of this Agreement by.any Party by means of fax, e-mail, PDF, or
other electronic transmission shall have the force and effect as delivery of a manually-signed
original.
Dated: | January 14, 2022
LETITIA JAMES
Attorney General of the State of New York
Attorney, for Petitioners
By: Unittiion HM. Bell
Valerie Singleton, AAG in Charge
Christina H, Bedell, AAG
200 Old Country Road, suite 240
Mineola, New York 11501
516.248.3302
ENTERED
Jan 20 2022
NASSAU COUNTY
COUNTY CLERK'S OFFICE
“A cone res
2 of 2
HAMBURGER, MAXSON, YAFFE
& MARTINGALE, LLP.
Attorneys for onde!
Richard Han er, Esq.
David N, Yaffe, Esq.
225 Broadholiow Road, Suite 301E
Melville, New York 11747
631.694.2400
Preview
(FILED: NASSAU COUNTY CLERK B1/20/2022 01:41 PM _ INDEX NO. 615766/2021 NYSCEF DOC. NO. Me oe RECEIVED NYSCEF: 01/14/2022 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF NASSAU eecennenene’ (eennewnnscnennceenesnnnmananncen, xX PEOPLE OF THE STATE OF NEW YORK, by LETITIA JAMES, Attorney General of the State s ORD of New York, i Petitioners, Index No.: 615766/2021 + against - | Assigned Justice: 5 CORNERS PET, INC.,, RISK ENTERPRISES, INC. d/b/a HON..HELEN VOUTSINAS SHAKE+A-PAW, and GERARD O’SULLIVAN and: MARC JACOBS, both individually and as.owners.of Shake-A-Paw, Respondents, aevenneenepnnnnnnmnnncnnnnncceaumeeunvennnnannnnncanennnnnnnewntrammanatimentone K IT IS HEREBY STIPULATED AND AGREED, by .and between. the undersigned, the attorneys of record for all the parties to.the above-entitled action, that SMB G P), is approved by: Petitioners as the independent veterinarian pursuant to the Order to Show Cause in‘this proceeding dated December 17, 2021, and-the:cost of his services shall be paid exclusively by Respondents, ¥T IS FURTHER STIPULATED. AND AGREED, (1) Dr. SRQRMMMMEER shall provide to Petitioners copies of all fit and unfit for sale health certificates issued by him in connection with his examiriations; (2) Respondents shall provide to Drammen for his review any medical and medication treatment records and transport records that he requests; (3) Dr. hall. examine all. puppies on the floor (not in isolation area) or on deposit that have not already been cleared by Petitioners’ veterinarians, with priority to puppies on deposit; (4) Dr. may conduct each examination in the manner he deems appropriate in his professional opinion and he is permitted to. bring an assistant-of his choosing to-assist with his examinations; and (5): Deal shall provide copies of notes taken. during the.éxaminations to all parties, including the fit and unfit for-sale health certificates; (6) Dr SERRE shall be permitted to do random walk-throughs and-conduct examinations where he deems appropriate at both Lynbrook and Hicksville locations without prior notice to both parties; (7) Dr. MEE and/or his assistant shall be permitted°to retrieve puppies thernselves from their enclosures, pens, and/or crates without interference from Respondents, Respondents’ employees, designees, agents and/or representatives; and (8) Dr. Qll—E@ will be permitted to obtain any samples from the dogs and/or perform x-rays, and order lab work to be performed:on saniples collected, should he find them necessary; E i : | 1 of 2INDEX NO. 615766/2021 RECEIVED NYSCEF: 01/14/2022 (FILED: NASSAU COUNTY CLERK BL/ze 2822 01:41 PM NYSCEF DOG. NO. 116 11T IS FURTHER STIPULATED AND AGREED, that this stipulation may be executed in separate counterparts, which together shall constitute the entirety of the Agreement. Delivery ofa signed:counterpart of this Agreement by.any Party by means of fax, e-mail, PDF, or other electronic transmission shall have the force and effect as delivery of a manually-signed original. Dated: | January 14, 2022 LETITIA JAMES Attorney General of the State of New York Attorney, for Petitioners By: Unittiion HM. Bell Valerie Singleton, AAG in Charge Christina H, Bedell, AAG 200 Old Country Road, suite 240 Mineola, New York 11501 516.248.3302 ENTERED Jan 20 2022 NASSAU COUNTY COUNTY CLERK'S OFFICE “A cone res 2 of 2 HAMBURGER, MAXSON, YAFFE & MARTINGALE, LLP. Attorneys for onde! Richard Han er, Esq. David N, Yaffe, Esq. 225 Broadholiow Road, Suite 301E Melville, New York 11747 631.694.2400