Preview
FILED: NEW YORK COUNTY CLERK 10/20/2022 10:36 PM INDEX NO. 652352/2018
NYSCEF DOC. NO. 228 RECEIVED NYSCEF: 10/20/2022
From: jnesq@jenesqlaw.com
To: Rimma Ayzen
Subject: RE: Stolper v. Burbacki
Date: Friday, October 14, 2022 3:08:35 PM
Attachments: image001.png
221014 Responses to Contention Interrogatories.pdf
Attached please find my client’s responses.
Thanks and have a nice Shabbat and rest of Sukkot.
LAW OFFICES OF JONATHAN E. NEUMAN, ESQ.
Jonathan E. Neuman, Esq.
176-25 Union Turnpike, Suite 230
Fresh Meadows, NY 11366
(347) 450-6710
THE CONTENT OF THIS E-MAIL AND ANY ATTACHMENT(S) HERETO IS INFORMATION PROTECTED BY
THE ATTORNEY-CLIENT AND/OR THE ATTORNEY WORK PRODUCT PRIVILEGE. IT IS INTENDED ONLY
FOR THE VIEWING AND USE OF THE INTENDED RECIPIENT AND PRIVILEGES ARE NOT WAIVED BY
VIRTUE OF THIS HAVING BEEN SENT VIA E-MAIL. IF THE PERSON ACTUALLY RECEIVING THIS E-MAIL
OR ANY READER OF THIS E-MAIL IS NOT THE NAMED RECIPIENT OR THE EMPLOYEE OR AGENT
RESPONSIBLE TO DELIVER THIS E-MAIL TO THE NAMED RECIPIENT, THEN ANY USE, DISSEMINATION,
DISTRIBUTION OR COPYING THIS E-MAIL OR ANY ATTACHMENT(S) IS STRICTLY PROHIBITED. IF YOU
RECEIVED THIS E-MAIL IN ERROR PLEASE FORWARD IT BACK TO OUR E-MAIL ADDRESS AT
JNESQ@JENESQLAW.COM.
From: jnesq@jenesqlaw.com
Sent: Sunday, October 9, 2022 5:41 PM
To: 'Rimma Ayzen'
Subject: RE: Stolper v. Burbacki
I’ll follow up with Zarina. Sukkot is starting shortly, so I won’t be able to email you before
Wednesday.
Enjoy the chag.
LAW OFFICES OF JONATHAN E. NEUMAN, ESQ.
Jonathan E. Neuman, Esq.
176-25 Union Turnpike, Suite 230
Fresh Meadows, NY 11366
(347) 450-6710
THE CONTENT OF THIS E-MAIL AND ANY ATTACHMENT(S) HERETO IS INFORMATION PROTECTED BY
THE ATTORNEY-CLIENT AND/OR THE ATTORNEY WORK PRODUCT PRIVILEGE. IT IS INTENDED ONLY
FOR THE VIEWING AND USE OF THE INTENDED RECIPIENT AND PRIVILEGES ARE NOT WAIVED BY
FILED: NEW YORK COUNTY CLERK 10/20/2022 10:36 PM INDEX NO. 652352/2018
NYSCEF DOC. NO. 228 RECEIVED NYSCEF: 10/20/2022
VIRTUE OF THIS HAVING BEEN SENT VIA E-MAIL. IF THE PERSON ACTUALLY RECEIVING THIS E-MAIL
OR ANY READER OF THIS E-MAIL IS NOT THE NAMED RECIPIENT OR THE EMPLOYEE OR AGENT
RESPONSIBLE TO DELIVER THIS E-MAIL TO THE NAMED RECIPIENT, THEN ANY USE, DISSEMINATION,
DISTRIBUTION OR COPYING THIS E-MAIL OR ANY ATTACHMENT(S) IS STRICTLY PROHIBITED. IF YOU
RECEIVED THIS E-MAIL IN ERROR PLEASE FORWARD IT BACK TO OUR E-MAIL ADDRESS AT
JNESQ@JENESQLAW.COM.
From: Rimma Ayzen
Sent: Friday, October 7, 2022 6:18 PM
To: jnesq@jenesqlaw.com
Subject: Stolper v. Burbacki
Hi Jonathan,
Shana tovah. Please advise as to the status of Defendant’s responses to Plaintiff’s contention
interrogatories that were served on September 15; the responses are now untimely even accounting
for a courtesy one-day extension from the Wednesday due date.
Thanks,
Rimma Ayzen
RUSSO PLLC
350 Fifth Avenue, Suite 7230
New York NY 10118
+1 212 363 2000 www.russopllc.com
This email (and any attachments thereto) is intended only for use by the addressee(s) named herein and may contain legally
privileged and/or confidential information. If you are not the intended recipient of this email, you are hereby notified that
any dissemination, distribution or copying of this email (and any attachments thereto) is strictly prohibited. If you receive
this email in error please immediately notify me at (212) 363-2000 and permanently delete the original email (and any copy
of any email) and any printout thereof.
FILED: NEW YORK COUNTY CLERK 10/20/2022 10:36 PM INDEX NO. 652352/2018
NYSCEF DOC. NO. 228 RECEIVED NYSCEF: 10/20/2022
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF NEW YORK
----------------------------------X AND
S El I S RESPONSES
PE DEFENDANT'S
TO PLAINTIFF S
OBJECTIONS
Plaintiff,
INTERROGATORIES
-vs-
Index No. 652352/2018
ZARINA BURBACKI,
Defendant.
------------________.______________________Ç
follows to Plaintiff
Defendant, ZARINA responds and objects as
BURBACKI, hereby
STELLA STOLPER's Contention Interrogatories (the "Requests").
SPECIFIC OBJECTIONS AND RESPONSES
INTERROGATORIES
1. the individual who owned or whose name was otherwise associated
Identify or entity
with the bank account in as it appears in the Bank Statements, including on January
ending 9717,
26, 2016, March 4, 2016, April 15, 2016, April 26, 2016, and November 20, 2017.
Response: Zarina Burbacki and Burbacki Law Group
2. Identify the individual or entity who owned or whose name was otherwise associated
with the bank account ending in 5095, as itappears in the Bank Statements, including on March
t tr
9, 2017. ,
Response: Stella Bulochnikov and Wikked Entertainment
3. Identify the client(s) on whose behalf you were holding, or the individual or who
entity
owned, the $139,700.00 that was the beginning balance on Bank Statement covering January 1,
2016 - 2016.
January 29,
Response: Inna Shuman, Ran Marcus, Burbacki Law Group, Consolidated Press Holdings, Avi
Shimrony, Adlyn LLC, Mariah Carey
1
FILED: NEW YORK COUNTY CLERK 10/20/2022 10:36 PM INDEX NO. 652352/2018
NYSCEF DOC. NO. 228 RECEIVED NYSCEF: 10/20/2022
4.
Identify every individual and/or and Wikked, for whom money
entity, other than Plaintiff
was held, deposited or accepted into the Escrow otherwise directly or indirectly
Account, or who
had over Account the
ownership any money that was deposited into or held in the Escrow during
Relevant Time Period.
Response: Inna Press Holdings, Avi
Shuman, Ran Marcus, Burbacki Law Group, Consolidated
Shimrony, Adlyn LLC, Mariah Carey
5. each transaction in the Deposits and Additions fields of the Bank Statements, by
Identify
date and transaction which represents that was deposited into and held in the
amount, money
Escrow Account for individual or other than Plaintiff or Wikked, or which was
any entity
deposited for the benefit of individual or other than Plaintiff or Wikked, and specify
any entity
the identity of each such individual and/or entity.
Response:
I/I6/16 $ 3,750,000.00 CPH to Adlyn
1/7/16 $ (17,500.00) To Zarina for Australia event
1/8/16 $ (13,700.50) To Zarina for reimbursement for Dr. Anna payment for Stella
1/8/16 $ (3,419,000.00) To Adlyn directed by Avi Shimrony
I/29/16 $ (181,000.00) To Yontan directed by Avi Shimrony
3/3/16 $ 28,000.00 To Zarina for SSF tour
3/4/16 $ 10,000.00 To Zarina for SSFtour prep
3/24/16 $ 13,000.00 To Zarina for SSFtour prep
3/4/16 $ (28,000.00)To Zarina for SSF tour
4/4/16 $ 14,000.00 To Zarina for SSF tour
4/6/16 $ 5,000.00 To Zarina for oneOak
4/7/16 $ 14,000.00 To Zarina for SSF tour
4/15/16 $ (28,000.00)To Zarina for SSF tour
4/15/16 $ (5,000.00)To Zarina for oneOak
4/26/16 $ (13,000.00)To Zarina for SSF tour
5/16/16 $ 500,000.00 For Mariah Carey
6/20/16 $ (450,000.00)For Mariah Carey
2
FILED: NEW YORK COUNTY CLERK 10/20/2022 10:36 PM INDEX NO. 652352/2018
NYSCEF DOC. NO. 228 RECEIVED NYSCEF: 10/20/2022
I1/15/16 $ 50,000.00 For Mariah Carey
12/15/16 $ Stella to Mariah
(11,976.28)To Zarina reimbursement for Winston gift given by
Harry
1/12/17 $ Shuman
(9,605.00)TO Jonathan Neuman Esq. for legal fees related to Dr.
2/21/17 $ 3,580.00 Dubai
To Zarina, reimbursement for Stella's dinner in
2/28/17 $ (67,500.00)TO client Marcus
2/28/17 $ (3,580.00)To Stella's dinner in Dubai
Zarina, reimbursement for
4/13/17 $ hairdresser for Stella's extensio
(550.00)To Zarina, reimbursement for paying Nora the
4/13/17 $ (125,000.00)To Zarina for RNC/South of France deal
4/13/17 $ with Packer/Mariah deal where she mad
(25,000.00)To Zarina as gift from Stella for help
11/20/17 $ (10,000.00)To Zarina from Adlyn
3/2/18 $ 10,000.00 Reimbursement to Adlyn from Zarina
4/5/18 $ (150,000.00)To Adlyn
6. With regard to each of the wire transfers, withdrawals and/or other electronic
following
transactions from the Escrow Account, all details regarding the transaction including the
identify
business purpose of the transaction, the goods or services in payment of which the transaction
was made, the date of Defendant's request to make such transfer or notice to Plaintiff regarding
such transfer, and Plaintiff's request or permission to make the transfer, or acknowledgement of
the transfer or Defendant's notice thereof. Produce alldocuments upon which your responses are
based, to the extent they have not already been produced.
A) January 8, 2016 online transfer in the amount of $17,500 to 0846
" Payment from Mariah for services rendered to Australia
Carey relating
NYE Event; sent by Mariah's business management to escrow so that
upon receipt into the escrow, it would then be transferred Zarina to
by
Zarina's personal account.
B) January 26, 2016 online transfer in the amount of $13,700 to account 9717
" Stella's card was declined when she was plastic on her
getting surgery
chin (at Dr. Anna's). Zarina was with Stella and paid for her procedure
and Stella told Zarina to deduct the expense from the escrow funds for
reimbursement.
3
FILED: NEW YORK COUNTY CLERK 10/20/2022 10:36 PM INDEX NO. 652352/2018
NYSCEF DOC. NO. 228 RECEIVED NYSCEF: 10/20/2022
C) April 15, 2016 online 0846
transfer in the amount of $5,000 to account
" Tour and
Zarina and Stella were in Europe for the Sweet Sweet Fantasy
were out of pocket;
many expenses towards Stella and her kids going
a card associated
Stella said to transfer $5k to Zarina's card (I didn't have
to expenses for Stella and her
the escrow) and Zarina paid for personal
Zarina took on for Stella
kids from this (it didn't cover allthe expenses
and her kids.)
D) April 15, 2016 online transfer of $28,000 to account 9717
" 4th paid Mariah for invoices
On April and April 7th,Zarina WaS by Carey
for 3/28-
for Sweet Sweet Tour from 3/28-4/11/16 and an invoice
Fantasy
then transferred to Zarina's business account on April 15,
4/11/16. It was
2016.
April 2017 online transfer in the amount of $13,000 to account 9717
E) 26,
" On March Zarina was paid $13,000 for the Sweet Sweet Fantasy
24, 2016,
Tour as per the invoice. It was then transferred to Zarina.
prep
F) January 12, 2017 wire transfer to Jonathan E. Neuman Attorney Trust
" Jonathan E. Neuman was co-counsel on client Inna Shuman's case and
these were expenses related to services provided on the account.
G) February 28, 2017 online transfer of $3,580 to account ending in 2566
" Stella's card was declined in Dubai and Zarina covered her bill and on
2/21/17 Zarina received reimbursement to the escrow account for the
expense, and then transferred it to the 345 Account.
Consulting
H) February 28, 2017 online wire transfer in the amount of $67,500
" $67,500 were client funds of a client named Ran Marcus and transferred to
him during representation of said client.
I) March 9, 2017 transfer in the amount of $25,000 to account 5095
" Sent to Stella's Chase account at her request.
J) November 20, 2017 online transfer in the amount of $10,000 in 9717
ending
" Sent to Burbacki Law P.C. per
Group approval from Avi Shimrony.
4
FILED: NEW YORK COUNTY CLERK 10/20/2022 10:36 PM INDEX NO. 652352/2018
NYSCEF DOC. NO. 228 RECEIVED NYSCEF: 10/20/2022
Defendant reserves the right to additional
supplement and amend these responses in the event
information becomes available.
Dated: Fresh
Meadows, New York
October 12, 2022
Jonathan E. Neuman, Esq.
Attorney for Defendant
176-25 Union Turnpike, Suite 230
Fresh Meadows, NY 11366
(347) 450-6710
(718) 228-3689 facsimile
jnesq@jenesqlaw.com
5
FILED: NEW YORK COUNTY CLERK 10/20/2022 10:36 PM INDEX NO. 652352/2018
NYSCEF DOC. NO. 228 RECEIVED NYSCEF: 10/20/2022
AFFIDAVIT
STATE OF NEW YORK )
) ss.:
COUNTY OF QUEENS )
ZARINA
BURBACKI, being duly sworn, deposes and says under penalty of perjury that:
The answers
foregoing to Plaintiff's Interrogatories made me are true. I am aware that
by
if the answers
foregoing given by me are willfully false, I may be subject to punishment.
BURBACKI
Sworn to and Subscribed to before me
12tli
this day of October, 2022.
Cotary Public
NEUMAN
6
Preview
FILED: NEW YORK COUNTY CLERK 10/20/2022 10:36 PM INDEX NO. 652352/2018 NYSCEF DOC. NO. 228 RECEIVED NYSCEF: 10/20/2022 From: jnesq@jenesqlaw.com To: Rimma Ayzen Subject: RE: Stolper v. Burbacki Date: Friday, October 14, 2022 3:08:35 PM Attachments: image001.png 221014 Responses to Contention Interrogatories.pdf Attached please find my client’s responses. Thanks and have a nice Shabbat and rest of Sukkot. LAW OFFICES OF JONATHAN E. NEUMAN, ESQ. Jonathan E. Neuman, Esq. 176-25 Union Turnpike, Suite 230 Fresh Meadows, NY 11366 (347) 450-6710 THE CONTENT OF THIS E-MAIL AND ANY ATTACHMENT(S) HERETO IS INFORMATION PROTECTED BY THE ATTORNEY-CLIENT AND/OR THE ATTORNEY WORK PRODUCT PRIVILEGE. IT IS INTENDED ONLY FOR THE VIEWING AND USE OF THE INTENDED RECIPIENT AND PRIVILEGES ARE NOT WAIVED BY VIRTUE OF THIS HAVING BEEN SENT VIA E-MAIL. IF THE PERSON ACTUALLY RECEIVING THIS E-MAIL OR ANY READER OF THIS E-MAIL IS NOT THE NAMED RECIPIENT OR THE EMPLOYEE OR AGENT RESPONSIBLE TO DELIVER THIS E-MAIL TO THE NAMED RECIPIENT, THEN ANY USE, DISSEMINATION, DISTRIBUTION OR COPYING THIS E-MAIL OR ANY ATTACHMENT(S) IS STRICTLY PROHIBITED. IF YOU RECEIVED THIS E-MAIL IN ERROR PLEASE FORWARD IT BACK TO OUR E-MAIL ADDRESS AT JNESQ@JENESQLAW.COM. From: jnesq@jenesqlaw.com Sent: Sunday, October 9, 2022 5:41 PM To: 'Rimma Ayzen' Subject: RE: Stolper v. Burbacki I’ll follow up with Zarina. Sukkot is starting shortly, so I won’t be able to email you before Wednesday. Enjoy the chag. LAW OFFICES OF JONATHAN E. NEUMAN, ESQ. Jonathan E. Neuman, Esq. 176-25 Union Turnpike, Suite 230 Fresh Meadows, NY 11366 (347) 450-6710 THE CONTENT OF THIS E-MAIL AND ANY ATTACHMENT(S) HERETO IS INFORMATION PROTECTED BY THE ATTORNEY-CLIENT AND/OR THE ATTORNEY WORK PRODUCT PRIVILEGE. IT IS INTENDED ONLY FOR THE VIEWING AND USE OF THE INTENDED RECIPIENT AND PRIVILEGES ARE NOT WAIVED BY FILED: NEW YORK COUNTY CLERK 10/20/2022 10:36 PM INDEX NO. 652352/2018 NYSCEF DOC. NO. 228 RECEIVED NYSCEF: 10/20/2022 VIRTUE OF THIS HAVING BEEN SENT VIA E-MAIL. IF THE PERSON ACTUALLY RECEIVING THIS E-MAIL OR ANY READER OF THIS E-MAIL IS NOT THE NAMED RECIPIENT OR THE EMPLOYEE OR AGENT RESPONSIBLE TO DELIVER THIS E-MAIL TO THE NAMED RECIPIENT, THEN ANY USE, DISSEMINATION, DISTRIBUTION OR COPYING THIS E-MAIL OR ANY ATTACHMENT(S) IS STRICTLY PROHIBITED. IF YOU RECEIVED THIS E-MAIL IN ERROR PLEASE FORWARD IT BACK TO OUR E-MAIL ADDRESS AT JNESQ@JENESQLAW.COM. From: Rimma Ayzen Sent: Friday, October 7, 2022 6:18 PM To: jnesq@jenesqlaw.com Subject: Stolper v. Burbacki Hi Jonathan, Shana tovah. Please advise as to the status of Defendant’s responses to Plaintiff’s contention interrogatories that were served on September 15; the responses are now untimely even accounting for a courtesy one-day extension from the Wednesday due date. Thanks, Rimma Ayzen RUSSO PLLC 350 Fifth Avenue, Suite 7230 New York NY 10118 +1 212 363 2000 www.russopllc.com This email (and any attachments thereto) is intended only for use by the addressee(s) named herein and may contain legally privileged and/or confidential information. If you are not the intended recipient of this email, you are hereby notified that any dissemination, distribution or copying of this email (and any attachments thereto) is strictly prohibited. If you receive this email in error please immediately notify me at (212) 363-2000 and permanently delete the original email (and any copy of any email) and any printout thereof. FILED: NEW YORK COUNTY CLERK 10/20/2022 10:36 PM INDEX NO. 652352/2018 NYSCEF DOC. NO. 228 RECEIVED NYSCEF: 10/20/2022 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF NEW YORK ----------------------------------X AND S El I S RESPONSES PE DEFENDANT'S TO PLAINTIFF S OBJECTIONS Plaintiff, INTERROGATORIES -vs- Index No. 652352/2018 ZARINA BURBACKI, Defendant. ------------________.______________________Ç follows to Plaintiff Defendant, ZARINA responds and objects as BURBACKI, hereby STELLA STOLPER's Contention Interrogatories (the "Requests"). SPECIFIC OBJECTIONS AND RESPONSES INTERROGATORIES 1. the individual who owned or whose name was otherwise associated Identify or entity with the bank account in as it appears in the Bank Statements, including on January ending 9717, 26, 2016, March 4, 2016, April 15, 2016, April 26, 2016, and November 20, 2017. Response: Zarina Burbacki and Burbacki Law Group 2. Identify the individual or entity who owned or whose name was otherwise associated with the bank account ending in 5095, as itappears in the Bank Statements, including on March t tr 9, 2017. , Response: Stella Bulochnikov and Wikked Entertainment 3. Identify the client(s) on whose behalf you were holding, or the individual or who entity owned, the $139,700.00 that was the beginning balance on Bank Statement covering January 1, 2016 - 2016. January 29, Response: Inna Shuman, Ran Marcus, Burbacki Law Group, Consolidated Press Holdings, Avi Shimrony, Adlyn LLC, Mariah Carey 1 FILED: NEW YORK COUNTY CLERK 10/20/2022 10:36 PM INDEX NO. 652352/2018 NYSCEF DOC. NO. 228 RECEIVED NYSCEF: 10/20/2022 4. Identify every individual and/or and Wikked, for whom money entity, other than Plaintiff was held, deposited or accepted into the Escrow otherwise directly or indirectly Account, or who had over Account the ownership any money that was deposited into or held in the Escrow during Relevant Time Period. Response: Inna Press Holdings, Avi Shuman, Ran Marcus, Burbacki Law Group, Consolidated Shimrony, Adlyn LLC, Mariah Carey 5. each transaction in the Deposits and Additions fields of the Bank Statements, by Identify date and transaction which represents that was deposited into and held in the amount, money Escrow Account for individual or other than Plaintiff or Wikked, or which was any entity deposited for the benefit of individual or other than Plaintiff or Wikked, and specify any entity the identity of each such individual and/or entity. Response: I/I6/16 $ 3,750,000.00 CPH to Adlyn 1/7/16 $ (17,500.00) To Zarina for Australia event 1/8/16 $ (13,700.50) To Zarina for reimbursement for Dr. Anna payment for Stella 1/8/16 $ (3,419,000.00) To Adlyn directed by Avi Shimrony I/29/16 $ (181,000.00) To Yontan directed by Avi Shimrony 3/3/16 $ 28,000.00 To Zarina for SSF tour 3/4/16 $ 10,000.00 To Zarina for SSFtour prep 3/24/16 $ 13,000.00 To Zarina for SSFtour prep 3/4/16 $ (28,000.00)To Zarina for SSF tour 4/4/16 $ 14,000.00 To Zarina for SSF tour 4/6/16 $ 5,000.00 To Zarina for oneOak 4/7/16 $ 14,000.00 To Zarina for SSF tour 4/15/16 $ (28,000.00)To Zarina for SSF tour 4/15/16 $ (5,000.00)To Zarina for oneOak 4/26/16 $ (13,000.00)To Zarina for SSF tour 5/16/16 $ 500,000.00 For Mariah Carey 6/20/16 $ (450,000.00)For Mariah Carey 2 FILED: NEW YORK COUNTY CLERK 10/20/2022 10:36 PM INDEX NO. 652352/2018 NYSCEF DOC. NO. 228 RECEIVED NYSCEF: 10/20/2022 I1/15/16 $ 50,000.00 For Mariah Carey 12/15/16 $ Stella to Mariah (11,976.28)To Zarina reimbursement for Winston gift given by Harry 1/12/17 $ Shuman (9,605.00)TO Jonathan Neuman Esq. for legal fees related to Dr. 2/21/17 $ 3,580.00 Dubai To Zarina, reimbursement for Stella's dinner in 2/28/17 $ (67,500.00)TO client Marcus 2/28/17 $ (3,580.00)To Stella's dinner in Dubai Zarina, reimbursement for 4/13/17 $ hairdresser for Stella's extensio (550.00)To Zarina, reimbursement for paying Nora the 4/13/17 $ (125,000.00)To Zarina for RNC/South of France deal 4/13/17 $ with Packer/Mariah deal where she mad (25,000.00)To Zarina as gift from Stella for help 11/20/17 $ (10,000.00)To Zarina from Adlyn 3/2/18 $ 10,000.00 Reimbursement to Adlyn from Zarina 4/5/18 $ (150,000.00)To Adlyn 6. With regard to each of the wire transfers, withdrawals and/or other electronic following transactions from the Escrow Account, all details regarding the transaction including the identify business purpose of the transaction, the goods or services in payment of which the transaction was made, the date of Defendant's request to make such transfer or notice to Plaintiff regarding such transfer, and Plaintiff's request or permission to make the transfer, or acknowledgement of the transfer or Defendant's notice thereof. Produce alldocuments upon which your responses are based, to the extent they have not already been produced. A) January 8, 2016 online transfer in the amount of $17,500 to 0846 " Payment from Mariah for services rendered to Australia Carey relating NYE Event; sent by Mariah's business management to escrow so that upon receipt into the escrow, it would then be transferred Zarina to by Zarina's personal account. B) January 26, 2016 online transfer in the amount of $13,700 to account 9717 " Stella's card was declined when she was plastic on her getting surgery chin (at Dr. Anna's). Zarina was with Stella and paid for her procedure and Stella told Zarina to deduct the expense from the escrow funds for reimbursement. 3 FILED: NEW YORK COUNTY CLERK 10/20/2022 10:36 PM INDEX NO. 652352/2018 NYSCEF DOC. NO. 228 RECEIVED NYSCEF: 10/20/2022 C) April 15, 2016 online 0846 transfer in the amount of $5,000 to account " Tour and Zarina and Stella were in Europe for the Sweet Sweet Fantasy were out of pocket; many expenses towards Stella and her kids going a card associated Stella said to transfer $5k to Zarina's card (I didn't have to expenses for Stella and her the escrow) and Zarina paid for personal Zarina took on for Stella kids from this (it didn't cover allthe expenses and her kids.) D) April 15, 2016 online transfer of $28,000 to account 9717 " 4th paid Mariah for invoices On April and April 7th,Zarina WaS by Carey for 3/28- for Sweet Sweet Tour from 3/28-4/11/16 and an invoice Fantasy then transferred to Zarina's business account on April 15, 4/11/16. It was 2016. April 2017 online transfer in the amount of $13,000 to account 9717 E) 26, " On March Zarina was paid $13,000 for the Sweet Sweet Fantasy 24, 2016, Tour as per the invoice. It was then transferred to Zarina. prep F) January 12, 2017 wire transfer to Jonathan E. Neuman Attorney Trust " Jonathan E. Neuman was co-counsel on client Inna Shuman's case and these were expenses related to services provided on the account. G) February 28, 2017 online transfer of $3,580 to account ending in 2566 " Stella's card was declined in Dubai and Zarina covered her bill and on 2/21/17 Zarina received reimbursement to the escrow account for the expense, and then transferred it to the 345 Account. Consulting H) February 28, 2017 online wire transfer in the amount of $67,500 " $67,500 were client funds of a client named Ran Marcus and transferred to him during representation of said client. I) March 9, 2017 transfer in the amount of $25,000 to account 5095 " Sent to Stella's Chase account at her request. J) November 20, 2017 online transfer in the amount of $10,000 in 9717 ending " Sent to Burbacki Law P.C. per Group approval from Avi Shimrony. 4 FILED: NEW YORK COUNTY CLERK 10/20/2022 10:36 PM INDEX NO. 652352/2018 NYSCEF DOC. NO. 228 RECEIVED NYSCEF: 10/20/2022 Defendant reserves the right to additional supplement and amend these responses in the event information becomes available. Dated: Fresh Meadows, New York October 12, 2022 Jonathan E. Neuman, Esq. Attorney for Defendant 176-25 Union Turnpike, Suite 230 Fresh Meadows, NY 11366 (347) 450-6710 (718) 228-3689 facsimile jnesq@jenesqlaw.com 5 FILED: NEW YORK COUNTY CLERK 10/20/2022 10:36 PM INDEX NO. 652352/2018 NYSCEF DOC. NO. 228 RECEIVED NYSCEF: 10/20/2022 AFFIDAVIT STATE OF NEW YORK ) ) ss.: COUNTY OF QUEENS ) ZARINA BURBACKI, being duly sworn, deposes and says under penalty of perjury that: The answers foregoing to Plaintiff's Interrogatories made me are true. I am aware that by if the answers foregoing given by me are willfully false, I may be subject to punishment. BURBACKI Sworn to and Subscribed to before me 12tli this day of October, 2022. Cotary Public NEUMAN 6