On May 31, 2017 a
Motion-Secondary
was filed
involving a dispute between
Christian Russell,
and
Houslanger & Associates, Pllc,
Todd E Houslanger,
for Other Matters - Consumer Credit (Non-Card) Transaction
in the District Court of New York County.
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FILED: NEW YORK COUNTY CLERK 12/05/2017 03:50 PM INDEX NO. 154967/2017
NYSCEF DOC. NO. 12 RECEIVED NYSCEF: 12/05/2017
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF NEW YORK
________________________________________________________________________
CHRISTIAN RUSSELL,
INDEX NO. 154967/2017
Plaintiff,
-against- AFFIRMATION
HOUSLANGER & ASSOCIATES, PLLC,
AND TODD E. HOUSLANGER,
Defendants.
________________________________________________________________________
Mitchell L. Pashkin, an attorney at law duly admitted to practice in the courts of the
State of New York, hereby affirms under penalties of perjury as follows:
1. I am the attorney for Plaintiff.
2. On October 3, 2017, Defendants served their Demand For Complaint via filing it on
NYSCEF. Per the aforementioned Demand For Complaint, Plaintiff had to file his
Complaint by Monday October 23, 2017. Therefore, I placed an entry into my
calendar on Friday October 20, 2017 to file the Complaint by Monday October 23,
2017.
3. I mistakenly overlooked the aforementioned entry in my calendar; and as a result, I
did not file the Complaint.
4. On October 25, 2017, two days after the aforementioned deadline for Plaintiff to file
his Complaint, Defendants filed their Motion to Dismiss based on this failure to file
the Complaint.
5. Because of this Motion to Dismiss, I did not wind up filing a Complaint. Instead, I
decided to seek permission to file a late Complaint pursuant to a Cross-Motion in
response to Defendants’ Motion to Dismiss.
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FILED: NEW YORK COUNTY CLERK 12/05/2017 03:50 PM INDEX NO. 154967/2017
NYSCEF DOC. NO. 12 RECEIVED NYSCEF: 12/05/2017
6. Exhibit A is Plaintiff’s Affidavit.
7. Exhibit B is a proposed Complaint.
8. Plaintiff consents to the dismiss against the individual Defendant Todd E.
Houslanger.
Dated: December 5, 2017
/s/_________________________
Mitchell L. Pashkin, Esq.
Attorney For Plaintiff
775 Park Avenue, Ste. 255
Huntington, NY 11743
(631) 335-1107
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FILED: NEW YORK COUNTY CLERK 12/05/2017 03:50 PM INDEX NO. 154967/2017
NYSCEF DOC. NO. 12 RECEIVED NYSCEF: 12/05/2017
Index No. 154967/2017
________________________________
CHRISTIAN RUSSELL,
Plaintiff,
-vs-
HOUSLANGER & ASSOCIATES, PLLC
AND TODD E. HOUSLANGER,
Defendants.
________________________________
AFFIRMATION
IN SUPPORT OF CROSS-MOTION
________________________________
Mitchell L. Pashkin certifies that, to the
best of his knowledge, information and
belief, formed after an inquiry
reasonable under the circumstances, the
presentation of the annexed paper(s) or
the contentions therein are not frivolous
as defined in 22 NYCRR 130-1.1.(c).
/s/_______________________
Mitchell L. Pashkin, Esq.
Attorney For Defendant
775 Park Avenue, Ste. 255
Huntington, NY 11743
Tel.: 631.629.7709
Fax.: 631.824-9328
mpash@verizon.net
3 of 3
Document Filed Date
December 05, 2017
Case Filing Date
May 31, 2017
Category
Other Matters - Consumer Credit (Non-Card) Transaction
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FILED: NEW YORK COUNTY CLERK 12/05/2017 03:50 PM INDEX NO. 154967/2017 NYSCEF DOC. NO. 12 RECEIVED NYSCEF: 12/05/2017 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF NEW YORK ________________________________________________________________________ CHRISTIAN RUSSELL, INDEX NO. 154967/2017 Plaintiff, -against- AFFIRMATION HOUSLANGER & ASSOCIATES, PLLC, AND TODD E. HOUSLANGER, Defendants. ________________________________________________________________________ Mitchell L. Pashkin, an attorney at law duly admitted to practice in the courts of the State of New York, hereby affirms under penalties of perjury as follows: 1. I am the attorney for Plaintiff. 2. On October 3, 2017, Defendants served their Demand For Complaint via filing it on NYSCEF. Per the aforementioned Demand For Complaint, Plaintiff had to file his Complaint by Monday October 23, 2017. Therefore, I placed an entry into my calendar on Friday October 20, 2017 to file the Complaint by Monday October 23, 2017. 3. I mistakenly overlooked the aforementioned entry in my calendar; and as a result, I did not file the Complaint. 4. On October 25, 2017, two days after the aforementioned deadline for Plaintiff to file his Complaint, Defendants filed their Motion to Dismiss based on this failure to file the Complaint. 5. Because of this Motion to Dismiss, I did not wind up filing a Complaint. Instead, I decided to seek permission to file a late Complaint pursuant to a Cross-Motion in response to Defendants’ Motion to Dismiss. 1 of 3 FILED: NEW YORK COUNTY CLERK 12/05/2017 03:50 PM INDEX NO. 154967/2017 NYSCEF DOC. NO. 12 RECEIVED NYSCEF: 12/05/2017 6. Exhibit A is Plaintiff’s Affidavit. 7. Exhibit B is a proposed Complaint. 8. Plaintiff consents to the dismiss against the individual Defendant Todd E. Houslanger. Dated: December 5, 2017 /s/_________________________ Mitchell L. Pashkin, Esq. Attorney For Plaintiff 775 Park Avenue, Ste. 255 Huntington, NY 11743 (631) 335-1107 2 of 3 FILED: NEW YORK COUNTY CLERK 12/05/2017 03:50 PM INDEX NO. 154967/2017 NYSCEF DOC. NO. 12 RECEIVED NYSCEF: 12/05/2017 Index No. 154967/2017 ________________________________ CHRISTIAN RUSSELL, Plaintiff, -vs- HOUSLANGER & ASSOCIATES, PLLC AND TODD E. HOUSLANGER, Defendants. ________________________________ AFFIRMATION IN SUPPORT OF CROSS-MOTION ________________________________ Mitchell L. Pashkin certifies that, to the best of his knowledge, information and belief, formed after an inquiry reasonable under the circumstances, the presentation of the annexed paper(s) or the contentions therein are not frivolous as defined in 22 NYCRR 130-1.1.(c). /s/_______________________ Mitchell L. Pashkin, Esq. Attorney For Defendant 775 Park Avenue, Ste. 255 Huntington, NY 11743 Tel.: 631.629.7709 Fax.: 631.824-9328 mpash@verizon.net 3 of 3