Motion in Limine Evidentiary in People Of The State Of New York By ATTORNEY GERNERAL OF THE STATE OF NEW YORK v. 5 Corners Pet Inc, Risk Enterprises Inc Dba Shake-A-Paw, Gerard O'Sulllivan, Marc Jacobs Both Indvidually And As Owners Of SHAKE-A-PAW| Trellis.Law

On December 16, 2021 a Motion-Secondary was filed involving a dispute between People Of The State Of New York By Attorney Gerneral Of The State Of New York, and 5 Corners Pet Inc, Gerard O'Sulllivan, Marc Jacobs Both Indvidually And As Owners Of Shake-A-Paw, Risk Enterprises Inc Dba Shake-A-Paw, for Special Proceedings - Other (Pursuant to Exec Law 6312) in the District Court of Nassau County.

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FILED: NASSAU COUNTY CLERK 04/18/2022 02:41 PM INDEX NO. 615766/2021
NYSCEF DOC. NO. 289 RECEIVED NYSCEF: 04/18/2022

SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF NASSAU
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PEOPLE OF THE STATE OF NEW YORK, by
LETITIA JAMES, Attorney General of the State AFFIRMATION IN
of New York, SUPPORT OF MOTION
IN LIMINE
Petitioner,
- against - Index No.: 615766/2021

5 CORNERS PET, INC., RISK ENTERPRISES, INC. d/b/a Assigned Justice:
SHAKE-A-PAW, and GERARD O’SULLIVAN and MARC HON. HELEN VOUTSINAS
JACOBS, both individually and as owners of Shake-A-Paw,

Respondents.

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RICHARD HAMBURGER, an attorney at law, duly licensed to practice in

the State of New York, affirms under penalties of perjury as follows:

INTRODUCTION

1. I am a member of the firm of Hamburger, Maxson, Yaffe &

Martingale, LLP, attorneys for respondents 5 Corners Pet, Inc., Rick Enterprises, Inc.

d/b/a Shake A Paw, and Gerard O’Sullivan and Marc Jacobs, both individually and as

owners of Shake A Paw (collectively, “Respondents”) in this special proceeding, and I am

fully familiar with the facts and circumstances stated herein.

2. This affirmation is submitted in support of Respondents’ motion in

limine, seeking to preclude Petitioner from introducing and presenting at the hearing

ordered by the Court in its Short Form Order dated April 7, 2022 (the “Order”):

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a. all documentary, testimonial and expert evidence that was not

made and presented in the papers filed by Petitioner in support of the Order to Show

Cause dated December 17, 2021 (the “OSC”);

b. all evidence from the veterinarians designated by NYAG to

examine puppies at the Shake A Paw stores prior to Christmas 2021;

c. all evidence from Dr. Gregory Nelson, D.V.M.;

d. all evidence regarding alleged complaints from customers to

the Petitioner and/or to the Better Business Bureau that were referenced, but not

identified, specified and presented in the papers filed by Petitioner in support of the

OSC; and

e. all evidence regarding Small Claims Court records.

THE GOVERNING LAW

3. “[T]he function of a motion in limine is to permit a party to obtain a

preliminary order before or during trial excluding the introduction of anticipated

inadmissible, immaterial, or prejudicial evidence or limiting its use.” State v. Metz, 241

A.D.2d 192, 198 (1st Dept. 1998) (emphasis in original). The proper focus of a motion in

limine is whether evidence that a party anticipates offering is inadmissible. PCK Dev. Co.

LLC v. Assessor of Town of Ulster, 43 A.D.3d 539, 540 (3d Dept. 2007).

4. In addition, when issues have been resolved pursuant to prior

motion practice, their resolution is then the “law of the case” and a trial Judge should

exclude evidence on such resolved issues in the context of a motion in limine. Siewert v.

Loudonville Elementary Sch., 210 A.D.2d 568, 569 (3d Dept. 1994); Wasson v. Bond, 80

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A.D.3d 1114, 1115 (3d Dept. 2011); and Metro. Steel Indus., Inc. v. Perini Corp. 55

A.D.3d 228, 231 (1st Dept. 2008). “The doctrine of the ‘law of the case’ is a rule of practice,

an articulation of sound policy that, when an issue is once judicially determined, that

should be the end of the matter as far as Judges and courts of co-ordinate jurisdiction are

concerned.” Martin v. City of Cohoes, 37 N.Y.2d 162, 165 (1975). In Ennist v. Shepherd,

117 A.D.2d 580 (2d Dept. 1986), for example, the Second Department recognized that a

protective order issued by one judge limiting discovery and inspection to certain financial

records “became the law of the case with respect to a court of co-ordinate jurisdiction and

was properly followed” by a different Special Term Judge.

POINT I

ALL EVIDENCE THAT WAS NOT PRESENTED IN THE
PAPERS FILED BY PETITIONER IN SUPPORT OF THE
OSC, OR WHICH WAS FIRST SUBMITTED BY
PETITIONER ON REPLY, SHOULD BE PRECLUDED.

5. In the prior motion practice before this Court, Respondents objected

to multiple affidavits and documents submitted by Petitioners in their reply papers, and

asserted that the Court should thus reject:

a. The affidavits and testimony of Petitioner’s veterinarians

Ashley Newman, D.V.M., Kayla Akkaya, D.V.M., Lauryn Benson, D.V.M., Ellen Gunzel,

D.V.M. and Diane Monsein Levitan, V.M.D. (NYSCEF Docs. 202, 203, 225, 226, 227,

228, 245, 276) that purports to present new evidence and arguments and were not

submitted as part of Petitioner’s forward-going case;

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b. the affidavit and testimony of Dr. Julie Fixman, D.V.M.

(NYSCEF Doc. No. 205 and 229) that purports to submit new evidence and arguments

and was not submitted as part of Petitioner’s forward-going case;

c. the new consumer affidavits and testimony that purport to

submit new evidence and arguments and were not submitted as part of Petitioner’s

forward-going case (i.e., the affidavits of Afua Boakye-Yiadon, Deborah Cassata, Marilyn

Cintron, Elaine Delasho, Shannon Greenhalgh, Roger Hoelderlin, Leila Joseph, Gianna

Lallos, William McCaffrey, Joanna McDonald, Alyssa McLoone, Marie Miceli, Latoya

Price-Felician, Thomas Riordan, Daniel Ruckert, Juhnee Shelton and Dara Williams

(NYSCEF Doc. Nos. 247-263));

d. the affidavit and testimony of Matthew Roper (NYSCEF Doc.

Nos. 204 and 250) that purports to submit new evidence and arguments and was not

submitted as part of Petitioner’s forward-going case;

e. (i) a spreadsheet of a list of complaints allegedly filed with the

Better Business Bureau (NYSCEF Doc. No. 188 and No. 231); (ii) one hundred eleven

pages of alleged supplemental medical records (NYSCEF Doc. No. 200, 244 and 275);

(iii) third party subpoenas and correspondence with third parties (NYSCEF Doc. Nos.

191-194, 237-240, 243, 268-271, 274); (iv) customer information sheets (NYSCEF Doc.

No. 233 and 265); and (v) an advocacy document with allegations (NYSCEF Doc. No.

234), all of which purported to submit new evidence and arguments and were not

submitted as part of Petitioner’s forward-going case; and

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f. any and all other evidence not presented in the papers filed

by Petitioner in support of the OSC.

6. In resolving these issues, this Court has already held and found:

The Court notes that in their reply papers, Petitioners have
improperly submitted new arguments and evidence, with
several affidavits, in support of new allegations not previously
made. It is well-settled ‘[t]he function of reply papers is to
address arguments made in opposition to the position taken
by the movant and not to permit the movant to introduce new
arguments in support of, or new grounds or evidence for, the
motion.’ (Lee v. Law Offices of Kim & Bae, P.C., 161 AD3d 964,
965 [2d Dept. 2018]; see also Azzopardi v. American Blower
st
Corp., 192 AD2d 453, 454 [1 Dept 1993]) (‘Indeed, the court
should never even have considered arguments making their
initial appearance in reply papers’); Migdol v. City of N.Y. 291
AD2d 201 [1st Dept 2002]) (affirming the rejection of reply
papers that ‘sought to remedy [] basic deficiencies in
appellant’s prima facie showing’). In Lee, the Second
Department affirmed the Nassau County Supreme Court’s
(Iannacci, J.) rejection of reply papers that violated these
rules, instructing:

Here, the plaintiff’s reply papers included new
arguments in support of the motion, new grounds
and evidence for the motion, and expressly requested
relief that was dramatically unlike the relief sought in
her original motion. Therefore, those contentions,
and the grounds and evidence in support of them
were not properly before the Supreme Court. (Lee,
supra, 161 AD3d at 965-66) (citations omitted).

Order, pp. 13-14.

7. The scope of this required preclusion necessarily includes any expert

affidavit or testimony prepared in reply to the Respondents’ expert affidavit, which may

not be considered for the purpose of determining whether the movant met its initial

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burden. See, e.g., Korthas v. U.S. Foodservice of Buffalo, Inc., 61 A.D.3d 1407 (4th Dept.

2009) (“We do not consider the affidavit of defendant’s expert meteorologist in

determining whether defendant met its initial burden because that affidavit was

submitted in reply to the affidavit of plaintiffs’ expert meteorologist”); accord, Walter v.

United Parcel Service, Inc., 56 A.D.3d 1187 (4th Dept. 2008).

8. The Court’s ruling in this regard stands as the law of the case.

Accordingly, all of the affidavits and documents specified above in paragraph 5(a), (b),

(c), (d), (e), and (f), and all arguments, documentary evidence and testimonial evidence,

including expert evidence, based upon, arising out of, or related to those affidavits, or

from those affiants should be precluded from the hearing.

POINT II

ALL EVIDENCE FROM NYAG VETERINARIANS
NEWMAN, AKKAYA, BENSON, GUNZEL AND LEVITAN
SHOULD BE PRECLUDED UPON THE ADDITIONAL
GROUND THAT THEIR SUBMISSION VIOLATES THE
AGREEMENT AND REPRESENTATIONS MADE BY
NYAG CONCERNING THE LIMITED PURPOSE OF
THE NYAG VET EXAMINATIONS.

9. In addition to the reasons for preclusion set forth in Point I (supra),

this Court should also preclude all evidence from Ashley Newman, D.V.M., Kayla Akkaya,

D.V.M., Lauryn Benson, D.V.M., Ellen Gunzel, D.V.M. and Diane Monsein Levitan,

V.M.D. (the “NYAG Vets”), all of whom volunteered and were assembled by NYAG to

examine or oversee the examination of puppies at the Shake A Paw stores and clear them

for sale prior to Christmas 2021, on the additional ground that it was previously agreed

and specifically represented by Assistant Attorney General Valerie Singleton that the

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NYAG Vets would not present any evidence arising from these examination to support

NYAG’s case. Counsel for Shake A Paw and the Court expressly relied upon that

agreement and representation by Ms. Singleton in crafting the terms, on the record, that

would allow puppies at the Shake A Paw stores to be examined and cleared for sale prior

to Christmas.

10. At the conference held with the Court in Chambers on March 4,

2022, I voiced this same objection, and stated that Ms. Singleton had expressly agreed

that no evidence would be adduced from these NYAG Vet examinations, and that the sole

purpose of allowing the NYAG Vets to examine the puppies was to assure their health

and fitness for sale, and not for any investigatory or evidentiary purposes. The Court

expressed recalling the same. Yet Ms. Singleton denied making these statements.

11. Later in the afternoon of March 4, I ordered the transcript of

proceedings held on December 23, 2022. A copy of that 33-page transcript is attached

hereto as Exhibit “A.” As the Court can see, the following colloquy occurs at pages 23-

26:

THE COURT: Much appreciated because we don’t want any
miscommunication with these puppies either. We don’t want
to have them lingering. If they have issues, let’s address them.
Are there any other issues?

MS. SINGLETON: Your Honor, I just want to be very clear,
but with respect to producing notes, et cetera, we are not
doing that -- again, I want to be very mindful of assigning a
role that these doctors and technicians did not take on. I
don’t want any, potentially any liability being attached to
them. They are not certifying the dogs. We are just saying
we are going in just to make sure that these dogs are fit and
that –

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THE COURT: Ms. Singleton, there is a problem there and I
want you to be mindful of that problem. The problem is it’s
all fine and good when we all agree, but when you don’t
agree, when the two of you don't agree and we are faced with
potentially a dog who Mr. Hamburger says is fine and your
volunteer vet saying it’s not, then you are going to have to
bring in someone to say, hey, it’s not. Otherwise, I have
nothing to go by.

MS. SINGLETON: I understand that, your Honor, and then
at that point, I would retain somebody for that.

THE COURT: Very good, so we can all have an
understanding that these are volunteers. We are trying to
move the process along. I know there was an objection to Fox.
I am not so sure about Fox. I think this is the best avenue. I
really do.

MR. HAMBURGER: Can we put in the stipulation that the
Attorney General will direct the volunteer veterinarians not to
destroy any of their notes or any of the records that they made
even though she is not turning them over in case we need to
look at that down the road. I don’t want those destroyed on
dogs that they don’t pass.

MS. SINGLETON: Your Honor, just so we are clear and I
want to be very upfront, transparent. This is making me a
little uncomfortable and if we can’t have an agreement,
because, again, these guys, their medical malpractice
insurance does not cover, I don’t think -- now, I would have
to look into this, but I do not think that their medical
malpractice would cover this. I will have to talk to –

THE COURT: I don’t even know how that comes into play. I
think at this point, Mr. Hamburger, if the AG’s office has an
issue with the dog and it’s due to a volunteer voluntarily
looking at a dog, then they are going to have to bring in an
expert within a certain time frame, you know, within 48 to
72 hours to really examine the dog if they want to object to
the dog coming in because I don’t want to put the volunteers
in jeopardy also, but it’s just, you know, someone willing to
come in and look at these dogs and identify, just a second

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set of eyes and identify if there are any issues. It’s a little
complicated but we are working with it, so I just want
everybody to be aware that if there is an issue with the dog,
then the AG’s office has to come forward and identify the
issue with the dog with someone that is going to be willing
to tell the Court that there is an issue with the dog. So in that
instance, they are going to have to produce their records.
Otherwise, I am going to have to go with the certification of
Dr. Fox. That’s not something for the stipulation, but what
you can put in the stipulation is that this group of
volunteers, they are going to examine the dogs just for
fitness, not for the purpose of litigation, and that should any
issues arise with the dogs, that the AG’s office immediately
advise the respondents, and then we will take it from there. I
suspect that will be a conference.

MR. YAFFE: So in connection with that, your Honor, they are
not, these volunteers are not gathering evidence. They are
simply looking at dogs.

THE COURT: Well, that is what they are telling me.

MR. YAFFE: Right, so they want to look at medical records.
They are not taking the medical records back to the Attorney
General. They are not copying them, they are not
photographing them. They are looking at it as part of their
on-site evaluation. They are not gathering evidence for the
Attorney General, so we can put that in the order as well.

MS. SINGLETON: We have taken great steps to make it
extremely clear and the Court has made it extremely clear
that they are operating as independent evaluators. They are
not the agent of the Attorney General. We have made that
extremely and abundantly clear and that their only role --
they are not to look at the conditions of the store. They are
only there to examine the puppies and they only are
allowed to have access to records that relate to the
examination of the puppies and that is all, and that is all
that they are there to do, your Honor. They are not there to
gather additional evidence for the Attorney General.

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THE COURT: Okay.

(Emphasis added).

12. There is also a separate confirmatory email that I sent to Ms.

Singleton and Assistant Attorney General Christina Bedell on December 23, 2022, at 5:53

PM. after the December 23 conference with the Court, a copy of which is attached hereto

as Exhibit “B.” That email states:

Valerie and Christina,

Here is a revised stipulation in clean and redlined formats
which reflect the changes we are comfortable making. This
will also confirm your representation to me, taken out of the
stipulation at your request, that petitioners’ designated
veterinarians are not acting in an investigatory or evidence
gathering capacity, but are examining puppies solely to
assess their health and fitness for sale.

(Emphasis added).

13. As the December 23 transcript shows, the parties were to incorporate

what had been agreed at the conference into a stipulation. Ms. Singleton and I went back

and forth on the afternoon of December 23 and our last communication was my email

quoted above, which includes clean and redlined drafts. Neither Ms. Singleton nor Ms.

Bedell ever got back to me with respect to this latest draft and, frankly, it was a moot

point because by the end of the day on December 23, the OAG Vet examinations had

been concluded at both stores.

14. That the examinations by the OAG Vets was, by agreement, not to

be investigative or evidentiary also resolved issues that Respondents’ had raised with

regard to OAG Vet recordkeeping. This Court will remember that Respondents wanted

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to receive copies of all the notes or records generated by the OAG Vets and Ms. Singleton

opposed that request on the specific basis that the OAG Vet examinations would be used

for no purpose other than to assure the health of the puppies as fit for sale. Thus, Ms.

Singleton stated:

I just want to be very clear, but with respect to producing
notes, et cetera, we are not doing that -- again, I want to be
very mindful of assigning a role that these doctors and
technicians did not take on. I don't want any, potentially any
liability being attached to them. They are not certifying the
dogs. We are just saying we are going in just to make sure
that these dogs are fit and that --

(Exh. “A,” 12/23/21 Transcript, p. 23) (emphasis added)

15. This Court was equally clear that OAG would not be able to use the

OAG Vet examinations for investigative or evidentiary purposes, immediately stating:

THE COURT: Ms. Singleton, there is a problem there and I
want you to be mindful of that problem. The problem is it's
all fine and good when we all agree, but when you don't
agree, when the two of you don't agree and we are faced with
potentially a dog who Mr. Hamburger says is fine and your
volunteer vet saying it's not, then you are going to have to
bring in someone to say, hey, it's not. Otherwise, I have
nothing to go by.

MS. SINGLETON: I understand that, your Honor, and then
at that point, I would retain somebody for that.

THE COURT: Very good, so we can all have an
understanding that these are volunteers.

(Exh. “A,” 12/23/21 Transcript, p. 23) (emphasis added).

16. Any attempt by NYAG to submit testimony or documentary evidence

from Drs. Newman, Akkaya, Benson, Gunzel, and Levitan, or to present any testimony

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or documentary evidence based upon their examinations, is precluded by the NYAG’s

prior agreement and representations made on the record.

17. The NYAG must be estopped and precluded from violating the

terms of its representations and agreement that these veterinarians would not be

witnesses against Shake A Paw, and if there were disputes about the condition of the

puppies at the time they were examined, the NYAG would retain other experts to support

their case. Shake A Paw would not have acquiesced to allow the NYAG veterinarians to

come into their stores and examine their puppies, and present evidence and testify as

witness against Shake A Paw, without (at a minimum) having all the records of those

examinations, including lab test results and communications between the veterinarians

and NYAG. No proper veterinary records of these ad hoc examinations were ever made

or disclosed to Respondents who are completely in the dark.

18. Put another way, to allow these NYAG designated veterinarians to

present evidence and testify against Shake A Paw would be to reward NYAG for its

misrepresentations to the Court and counsel, and to allow Shake A Paw to be ambushed

at the hearing with evidence adduced and developed in clear and deliberate violation of

those representations.

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POINT III

PETITIONER SHOULD BE PRECLUDED FROM
PROVIDING ANY EXPERT EVIDENCE THROUGH DR.
JULIE FIXMAN BASED UPON ARGUMENTS OR
EVIDENCE THAT WERE NOT SUBMITTED AS PART
OF PETITIONER’S FORWARD-GOING CASE.
ALTERNATIVELY, DR FIXMAN’S EXPERT
TESTIMONY SHOULD BE LIMITED TO THE OPINION
PROVIDED IN HER AFFIDAVIT WITH RESPECT TO
THE ELEVEN CUSTOMER COMPLAINTS ALSO
ADDRESSED BY DR. STEVEN FOX, RESPONDENTS’
EXPERT WITNESS.

19. NYAG should be precluded from presenting expert evidence at the

hearing from Dr. Julie Fixman, because it was improper for NYAG to submit its first

expert evidence on reply, and not as part of its forward-going case. See Point I, supra; see

again, Korthas v. U.S. Foodservice of Buffalo, Inc., 61 A.D.3d 1407 (4th Dept. 2009) (“We

do not consider the affidavit of defendant’s expert meteorologist in determining whether

defendant met its initial burden because that affidavit was submitted in reply to the

affidavit of plaintiffs’ expert meteorologist”); accord, Walter v. United Parcel Service, Inc.,

56 A.D.3d 1187 (4th Dept. 2008).

20. Additionally, even were that limitation overlooked, Dr. Fixman

should be precluded from presenting any testimony or evidence based upon the NYAG

Vets affidavits, the affidavit submitted by Matthew Roper, the new customer affidavits,

and/or other documents, all presented by Petitioner for the first time in reply. See Point

II, supra.

21. At best, Dr. Fixman should be allowed to testify only as to the same

consumer complaints that Respondents’ expert Dr. Steven Fox addressed in his opposing

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affidavit, on the theory that Dr. Fixman was replying to Dr. Fox. There is no basis for

her to opine on the otherwise inadmissible reply evidence presented for the first time

through the NYAG veterinarians or Mr. Roper, or any other “new evidence.”

POINT IV

ALL EVIDENCE FROM DR. GREGORY NELSON, D.V.M.,
SHOULD BE PRECLUDED. IF NYAG IS PERMITTED
TO SUBMIT TESTIMONY FROM DR. NELSON, IT
MUST BE CONDITIONED UPON THE IMMEDIATE
PRODUCTION OF THE FULL, UN-REDACTED,
CERTIFIED TRANSCRIPT OF DR. NELSON’S
TESTIMONY PLUS ALL THE EXHIBITS UTILIZED
DURING THAT DEPOSITION. DR. NELSON SHOULD
ALSO BE PRECLUDED FROM PROVIDING NEW
EVIDENCE NOT PRESENTED IN THE PAPERS
SUBMITTED IN SUPPORT OF THE OSC.

22. In the prior motion practice before this Court, Respondents

objected to Petitioner’s use and heavy reliance upon 40 selected pages from a deposition

transcript of Dr. Gregory Nelson, D.M.V., maintaining that it was unequivocally

inadmissible. A true and correct copy of those 40 selected pages, which were annexed to

Petitioner’s papers in support of the OSC at NYSCEF Doc. No. 54, is annexed hereto as

Exhibit “C.” As we demonstrated, the issues with this document were numerous.

23. First, Petitioner failed to annex the full transcript, a signature page

for Dr. Nelson or a stenographer’s certification. Rather, the document is only 40 pages

of what is at least a 228-page transcript (assuming page 228 — the highest page number

of the 40 pages — was the final page of the transcript). See, Exh. “C.” Thus, at best the

document is only one-sixth of the full transcript. As for the 40 pages that are there,

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Petitioner did not even present them in sequential order, as the pages skip up and down

multiple times. Id.

24. Second, as for the 40 pages, Dr. Nelson’s testimony is further

obscured by heavy redaction. For no explicit reason, Petitioner even goes so far as to

redact the transcript page number on the second page of the exhibit. Id.

25. Third, equally troubling, it is completely unclear what documents

are referenced or reviewed by Dr. Nelson while testifying. No such disclosure was made

by NYAG in the affirmation of AAG Christina Bedell filed in support of the OSC (the

“Bedell Aff.,” NYSCEF Doc No. 2), or in the transcript itself.

26. As for the select medical records reviewed by Dr. Nelson in this

transcript, only once did NYAG use an identifying marker for the record being

referenced. There, the NYAG stated that they were showing Dr. Nelson an “Exhibit K”

for a client “Steve Pardue” and a “Patient Bruno.” See, Exh. “C,” p. 19 (Tr. p. 194:16).

A thorough review of the Central Veterinarian Associates records, where Dr. Nelson

works, annexed to the Bedell Aff. revealed that there is no such record for either that

“client” or “patient.” We do not know from where this record came. Perhaps the record

is a decade old and well outside the statute of limitations, but cherry picked by the NYAG

for its purposes. We do not know.

27. As for the few other medical records referenced in the transcript, no

identifying markers are used whatsoever. This is the case despite that each “Central

Veterinary Associates” record contained several potential identifying markers, like

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“account number,” owner’s name, pet name, date of birth, etc. See generally, Bedell Aff.,

Exh. “I.”

28. Dr. Nelson also testified that he had “79” records before him. See,

Exh. “C,” p.3 (Tr. p. 42:11). However, the production of Central Veterinary Associates

records attached to the Bedell Aff. (Exh. “I”) contained only 63 records. Of those 63

records, nine are complete duplicates,1 leaving only 54 different animal records. Whether

Case Info

Judge

Francis Ricigliano Track Judge’s New Case

Case No.

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Document Filed Date

April 18, 2022

Case Filing Date

December 16, 2021

County

Parties

5 Corners Pet Inc Defendant
Gerard O'sulllivan Defendant
HAMBURGER, RICHARD CHARLES Attorney for the Defendant
LOGUE, TONI ELISABETH Attorney for the Plaintiff
LYNCH, HELENA ANN Attorney for the Plaintiff
Marc Jacobs BOTH INDVIDUALLY AND AS OWNERS OF SHAKE-A-PAW Defendant
MAXSON, LANE T Attorney for the Defendant
NESE, DOROTHY OEHLER Attorney for the Plaintiff
People of the State of New York by ATTORNEY GERNERAL OF THE STATE OF NEW YORK Plaintiff
Risk Enterprises Inc dba Shake-A-Paw Defendant
SINGH, CHRISTINA H. Attorney for the Plaintiff
SINGLETON, VALERIE Attorney for the Plaintiff
YAFFE, DAVID NORMAN Attorney for the Defendant
CLARENCE GAYLOR Attorney
LILLIAN MOSLEY Attorney
NATHAN YAFFE Attorney
SARAH BISER Attorney
CONRAD SINGER Attorney
CHRISTINE BELL Attorneys for Plaintiffs
DAVID NARCISO Attorney
ANDREW MARTINGALE Attorneys for Defendants
JENNIFER FERRARO Attorney
SHARON NOLAN Attorneys for Plaintiffs
SARAH NOLAN Attorney
MATTHEW TEBO Attorney
AMY CHAITOFF Attorney
TARYN FITZGERALD Attorney
LETITIA JAMES Attorneys for Plaintiffs
RICHARD GRADY Attorneys for Defendants
MYLAN DENERSTEIN Attorney
LAURA ALLEN Attorney
RICHARD GEE Attorneys for Plaintiffs
BONNIE WESER Attorney
HERBERT BEDELL Attorney
STACY WOLF Attorney
JAMES MCGUIRE Attorney

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Motion-Secondary: People Of The State Of New York By ATTORNEY GERNERAL OF THE STATE OF NEW YORK v. 5 Corners Pet Inc, Risk Enterprises Inc Dba Shake-A-Paw, Gerard O'Sulllivan, Marc Jacobs Both Indvidually And As Owners Of SHAKE-A-PAW

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