On June 30, 2020 a
Motion-Secondary
was filed
involving a dispute between
Mishael Dickman,
and
Yeshiva Of South Shore,
for Torts - Child Victims Act
in the District Court of Nassau County.
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FILED: NASSAU COUNTY CLERK 04/24/2021 10:47 PM INDEX NO. 900082/2020
NYSCEF DOC. NO. 12 RECEIVED NYSCEF: 04/24/2021
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF NASSAU
------------------------------------------------------------------------x
MISHAEL DICKMAN, :
: Index No. 900082/2020
Plaintiffs, :
: AFFIRMATION OF
-against- : KAREN Y. BITAR
: IN SUPPORT OF
YESHIVA OF SOUTH SHORE, : MOTION TO DISMISS
:
Defendant. :
------------------------------------------------------------------------x
KAREN Y. BITAR, an attorney duly admitted to practice law in the Courts of this State,
hereby affirms the truth of the following under the penalties of perjury, pursuant to CPLR § 2106:
1. I am a Partner with the law firm Seyfarth Shaw LLP, counsel for Defendant Yeshiva
of South Shore (“YOSS”), in the above-referenced action. I respectfully submit this Affirmation
in support of YOSS’ motion, pursuant to CPLR § 3211(a)(7), to dismiss the Plaintiffs’ Amended
Complaint, dated February 4, 2021, with prejudice.
2. Annexed hereto as Exhibit A is a true and correct copy of Plaintiffs’ Amended
Complaint, dated February 4, 2021 (NYSCEF No. 3).
3. For the reasons set forth in the accompanying Memorandum of Law, YOSS
respectfully requests that the Court dismiss Plaintiff’s amended Complaint in its entirety, and with
prejudice.
Dated: New York, New York
April 23, 2021
/s/ Karen Y. Bitar
KAREN Y. BITAR
1 of 2
FILED: NASSAU COUNTY CLERK 04/24/2021 10:47 PM INDEX NO. 900082/2020
NYSCEF DOC. NO. 12 RECEIVED NYSCEF: 04/24/2021
WORD-COUNT CERTIFICATION
I hereby certify pursuant to Rule 202.8-b of the Uniform Civil Rules for the Supreme
Court and County Court (22 NYCRR § 202.8-b), that the total number of words in this
Affirmation, inclusive of point headings and footnotes and exclusive of the caption, table of
contents, table of authorities, and signature block, is 135.
This certification was prepared in reliance on the word-count function of Microsoft
Word, the word-processing system used to prepare the documents.
Dated: New York, New York
April 23, 2021
SEYFARTH SHAW LLP
By:/s/ Karen Y. Bitar
Karen Y. Bitar
2 of 2
Document Filed Date
April 24, 2021
Case Filing Date
June 30, 2020
Category
Torts - Child Victims Act
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FILED: NASSAU COUNTY CLERK 04/24/2021 10:47 PM INDEX NO. 900082/2020 NYSCEF DOC. NO. 12 RECEIVED NYSCEF: 04/24/2021 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF NASSAU ------------------------------------------------------------------------x MISHAEL DICKMAN, : : Index No. 900082/2020 Plaintiffs, : : AFFIRMATION OF -against- : KAREN Y. BITAR : IN SUPPORT OF YESHIVA OF SOUTH SHORE, : MOTION TO DISMISS : Defendant. : ------------------------------------------------------------------------x KAREN Y. BITAR, an attorney duly admitted to practice law in the Courts of this State, hereby affirms the truth of the following under the penalties of perjury, pursuant to CPLR § 2106: 1. I am a Partner with the law firm Seyfarth Shaw LLP, counsel for Defendant Yeshiva of South Shore (“YOSS”), in the above-referenced action. I respectfully submit this Affirmation in support of YOSS’ motion, pursuant to CPLR § 3211(a)(7), to dismiss the Plaintiffs’ Amended Complaint, dated February 4, 2021, with prejudice. 2. Annexed hereto as Exhibit A is a true and correct copy of Plaintiffs’ Amended Complaint, dated February 4, 2021 (NYSCEF No. 3). 3. For the reasons set forth in the accompanying Memorandum of Law, YOSS respectfully requests that the Court dismiss Plaintiff’s amended Complaint in its entirety, and with prejudice. Dated: New York, New York April 23, 2021 /s/ Karen Y. Bitar KAREN Y. BITAR 1 of 2 FILED: NASSAU COUNTY CLERK 04/24/2021 10:47 PM INDEX NO. 900082/2020 NYSCEF DOC. NO. 12 RECEIVED NYSCEF: 04/24/2021 WORD-COUNT CERTIFICATION I hereby certify pursuant to Rule 202.8-b of the Uniform Civil Rules for the Supreme Court and County Court (22 NYCRR § 202.8-b), that the total number of words in this Affirmation, inclusive of point headings and footnotes and exclusive of the caption, table of contents, table of authorities, and signature block, is 135. This certification was prepared in reliance on the word-count function of Microsoft Word, the word-processing system used to prepare the documents. Dated: New York, New York April 23, 2021 SEYFARTH SHAW LLP By:/s/ Karen Y. Bitar Karen Y. Bitar 2 of 2