Motion for Child Support in Sang Cheol Woo v. Charles C. Spackman| Trellis.Law

On May 23, 2017 a Motion-Secondary was filed involving a dispute between Sang Cheol Woo, and Charles C. Spackman, for Commercial Division in the District Court of New York County.

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SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF NEW YORK

Index No. 652795/2017
SANG CHEOL WOO,
Hon Justice O. Peter Sherwood,
Plaintiff/Judgment Creditor, J.S.C.
Part 49
v.
Motion Sequence # 3
CHARLES C. SPACKMAN,

Defendant/Judgment Debtor.

MEMORANDUM OF LAW OF SANG CHEOL WOO IN
(I) OPPOSITION TO MATALON SHWEKY ELMAN PLLC’S AND ELMAN
FRIEBERG PLLC’S MOTION FOR A PROTECTIVE ORDER AND
(II) SUPPORT OF MR. WOO’S CROSS-MOTION FOR GARNISHMENT

John Han
john.han@kobrekim.com.hk
Darryl Stein
Darryl.stein@kobrekim.com
KOBRE & KIM LLP
800 Third Avenue
New York, New York 10022
(212) 488-1200

Attorneys for Plaintiff/Judgment Creditor
Sang Cheol Woo
May 2, 2019

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TABLE OF CONTENTS
Table of Contents ........................................................................................................................... i
Table of Authorities ...................................................................................................................... ii
Preliminary Statement.................................................................................................................. 1
Factual Background...................................................................................................................... 3
I. Mr. Spackman causes over US $1 billion in losses to a Korean listed company, and this
Court enters judgment against him. .................................................................................... 3
II. Multiple courts find that Mr. Spackman has regularly used nominees to shield his assets
from Mr. Woo in response to the Korean judgment. .......................................................... 3
III. Mr. Spackman has already used Spackman Media Group—the entity that deposited funds
to the Movants’ trust account—to pay more than US $400,000 to attorneys for his legal
fees in connection with this matter. .................................................................................... 5
IV. Mr. Woo restrains Mr. Spackman’s assets, including the retainer funds. .......................... 6
Legal Argument ............................................................................................................................ 7
I. The retainer funds are Mr. Spackman’s property. .............................................................. 7
II. The restraining notice should remain in effect. .................................................................. 9
III. The retainer funds should be turned over to Mr. Woo...................................................... 11
Conclusion ................................................................................................................................... 12

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TABLE OF AUTHORITIES
Cases

M.M. v. T.M., 50 Misc. 3d 565 (Sup. Ct., Monroe Cnty. 2015) ................................................. 7, 8

Potter v. MacLean, 75 A.D.3d 686 (3d Dep’t 2010) ............................................................ 7, 8, 10

Ray v. Jama Prods., Inc., 74 A.D.2d 845 (2d Dep’t 1980) ............................................................. 9

S.E.C. v. Pentagon Capital Mgmt. PLC, No. 08 Civ. 3324(RWS), 2013 WL 5815374 (S.D.N.Y.
2013).................................................................................................................................... 10, 11

Statutes

C.P.L.R. § 5222 .......................................................................................................................... 7, 8

C.P.L.R. § 5225..................................................................................................................... 2, 7, 11

C.P.L.R. § 5227......................................................................................................................... 2, 11

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PRELIMINARY STATEMENT
Plaintiff Sang Cheol Woo submits this memorandum of law in opposition to Matalon

Shweky Elman PLLC’s (“MSE”) and Elman Frieberg PLLC’s (“EF”) (together, the “Movants’”)

motion for a protective order (the “Motion”) and in support of Mr. Woo’s cross-motion for

garnishment of Mr. Spackman’s assets in the Movants’ trust account (the “Cross-Motion”).

It has been nearly twenty years since Charles Spackman caused Littauer Technologies Inc.

to write down over US $1 billion and be delisted from the Korean KOSDAQ exchange, resulting

in immense losses to investors including Sang Cheol Woo. Yet despite Mr. Spackman’s

subsequent criminal conviction and the judgments entered against him by this Court and the

Korean courts, Mr. Spackman has failed to pay one penny of the debt that he owes to Mr. Woo.

Now, Mr. Spackman has added the Movants to his growing list of unpaid creditors, who find

themselves in the middle of Mr. Spackman’s refusal to pay this Court’s judgment. Mr. Woo is

sympathetic to the Movants’ situation. Nonetheless, because the retainer funds were restrained by

Mr. Woo as Mr. Spackman’s judgment creditor nearly one month before Movants first invoiced

against those funds, the Motion should be denied.

Mr. Spackman used a third-party nominee, Spackman Media Group PTE Limited

(“Spackman Media Group”) to deposit the retainer at issue into the Movants’ trust account. The

Movants argue that this money should be released to pay their invoices to Mr. Spackman, but New

York law is clear that such funds are the property of the judgment debtor and properly subject to

restraint when deposited by a third party for a judgment debtor’s benefit. Furthermore, Mr.

Spackman’s use of Spackman Media Group to pay his personal expenses falls within his consistent

pattern of using nominees to shield his assets from creditors. Since the Korean judgment was

entered against Mr. Spackman on September 29, 2011, he has continued to enrich himself through

a complex network of nominees throughout the world, leaving in his wake a trail of unpaid

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creditors. As a result, courts in Singapore and the BVI have issued worldwide freezing injunctions

in connection with the Korean judgment against Mr. Spackman, his business partner Richard Lee,

and four companies in the British Virgin Islands (“BVI”) owned in the name of Mr. Spackman’s

wife and his brother-in-law.

The same Singapore entity, Spackman Media Group, that deposited the retainer for Mr.

Spackman’s post-judgment legal services with the Movants has already paid for more than US

$400,000 of his legal fees in connection with enforcement of the Korean judgment. The deposit

to the Movants’ client trust account arrived after this Court entered the judgment against Mr.

Spackman; Movants performed the bulk of the work for Mr. Spackman (75% or US $25,728.10)

after the funds in the trust account were restrained, and, in their own words, “despite the

Restraining Notices” (Movants’ Br. at 8); and, critically, the Movants only invoiced against the

retainer held in trust for Mr. Spackman’s benefit after the restraining notices were served. The

governing law is clear: Deposits by third parties for the benefit of the judgment debtor, including

legal retainers, constitute assets of the debtor subject to execution and enforcement. This is

particularly true where, as here, there is substantial evidence showing that Spackman Media Group

is one of many nominees used by Mr. Spackman to shield his personal assets from his creditors.

Not only should the restraining notice be maintained, but the funds in the trust account

should be used to satisfy the judgment. Since the trust account funds are property of Mr.

Spackman, this Court should order the funds to be paid to Mr. Woo pursuant to Sections 5225(b)

and 5227 of the Civil Practice Law and Rules. For the reasons discussed below, the Motion for a

protective order should be denied and the Cross-Motion for garnishment of the retainer funds

should be granted.

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FACTUAL BACKGROUND
I. Mr. Spackman causes over US $1 billion in losses to a Korean listed company, and
this Court enters judgment against him.

This Court is already well-familiar with Mr. Spackman’s misconduct in Korea that led to

the Korean judgment, and this Court’s resulting entry of the New York judgment. Mr. Woo was

a minority shareholder in Littauer Technologies, a publicly listed company in Korea. Mr.

Spackman caused Littauer to enter into a self-dealing transaction, liquidated a substantial

percentage of outstanding shares of Littauer in three days, and thereby collected a profit of more

than US $100 million at the expense of Mr. Woo and Littauer’s other shareholders. (NYSCEF

#78 at 2.) Mr. Spackman was found liable in Korea—a judgment twice affirmed by the Supreme

Court of Korea—and this Court recognized the judgment pursuant to C.P.L.R. Article 53.

(NYSCEF #78.) This Court entered judgment on September 11, 2018 (NYSCEF #79); notice of

entry was served on September 13, 2018 (NYSCEF #80); and Mr. Spackman’s time to appeal later

expired. (See Spray Aff. ¶ 11.) Mr. Woo has sought discovery in aid of execution of the Korean

and New York judgments.

II. Multiple courts find that Mr. Spackman has regularly used nominees to shield his
assets from Mr. Woo in response to the Korean judgment.

Since this Court entered the judgment, courts in Singapore and the BVI have entered ex

parte freezing orders against Mr. Spackman and five other parties acting as his nominees.

Spackman uses some of the nominees to pay his personal expenses, and he uses others to profit

from businesses in a way that would not be detected by creditors. For example, his business partner

Richard Lee’s (“Spackman’s Partner”) assets were frozen based on evidence that he used

Singapore-based accounts to pay US $299,663 for Mr. Spackman’s personal expenses, including

his U.S. federal taxes and his legal fees in these proceedings. (See Stein Ex. 1 (hereinafter the

“Han Aff.”) ¶¶ 65-73; Stein Aff. Ex. 7 at 6-10.) In addition, Mr. Woo alleged that Mr. Spackman

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used four BVI companies owned by his wife, So Hee Kim, and brother-in-law, Jae Sung Kim, to

profit from self-dealing share swaps with a publicly traded public company in Singapore called

Spackman Entertainment Group Limited founded and controlled by Mr. Spackman (SGX: 40E).

(See Han Aff. ¶¶ 27-64, 82-89; see also Stein Aff. Exs. 6-7 (Freezing Orders).) Spackman

Entertainment is one of Korea’s leading entertainment production groups and behind such box-

office hits as Snowpiercer, The Priests, and most recently Default, which has grossed more than

US $27 million since its release.1

Mr. Woo alleged that Spackman Entertainment repeatedly overpaid the BVI companies for

securities while Mr. Spackman and Richard Lee operated Spackman Entertainment as

CEO/Executive Chairman and Interim CEO/Director, respectively. (Han Aff. ¶¶ 27, 28, 66, 67.)

It was alleged that the BVI companies bought the shares of another Spackman-related entity

(Spackman Media Group Limited) for as little as US $0.13 per share but sold them to Spackman

Entertainment for US $3.00 per share only a few months later, generating a profit of US $6,307,500

for investments held for less than a year. (Han Aff. ¶¶ 28, 52, 63.)2 Despite Mr. Spackman’s

control of the BVI entities, he and Mr. Lee allegedly signed off on public announcements that the

BVI entities were not related to any of the directors of Spackman Entertainment or their associates.

(Han Aff. ¶ 110; Stein Aff. Ex. 9 at 7, 15, 21, 28.) Through the transactions, the BVI companies

are believed to have accumulated a substantial (and possibly controlling) stake in the publicly

1
See Spackman Entertainment Group, http://www.spackmanentertainmentgroup.com (last
accessed May 2, 2019).
2
A table of the share swaps can be found in a table at Han Aff. ¶ 28, with supporting documents
at Stein Aff. Ex. 8 at 3, 7-8, 33-34, 44, 47-49. Evidence showing beneficial owners, shareholders,
and directors of the BVI entities can be found at Stein Aff. Ex. 2 at 2, 4-6, 8-15, 54-55, 58-59, 79;
Stein Aff. Ex. 3 at 3-4, 7-9, 12-14, 16, 23, 26, 28-32; Stein Aff. Ex. 4 at 2-3, 8, 13-14, 16, 18-22;
Stein Aff. Ex. 5 at 1-2, 4-11, 42, 45, 50, 53-55, 58.

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traded Korean entertainment company (Han Aff. ¶¶ 82-90), which has now been frozen pursuant

to the BVI and Singapore courts’ orders.3 Since Spackman Entertainment entered into the

transactions, its share price has plummeted 80%. (See Han Aff. ¶ 29.)

III. Mr. Spackman has already used Spackman Media Group—the entity that deposited
funds to the Movants’ trust account—to pay more than US $400,000 to attorneys for
his legal fees in connection with this matter.

Spackman Media Group, the entity that deposited funds to the Movants’ client trust

account, has already paid for more than US $400,000 in legal services for Mr. Spackman in

connection with proceedings to enforce the Korean judgment. On twelve different occasions

between July 27, 2017, and September 11, 2018, Spackman Media Group wired funds to Mr.

Spackman’s previous New York counsel, Quinn Emanuel Urquhart & Sullivan LLP (“Quinn

Emanuel”) for Mr. Spackman’s personal legal services. (See Stein Aff. Ex. 10 at 3-14.) In total,

Spackman Media transferred US $400,761 to Quinn Emanuel. This sum is in addition to US

$174,731 paid by Spackman’s Partner, Richard Lee, for the same purpose. (See Han Aff. ¶ 69;

Stein Aff. Ex. 10 at 1-2.)

Consistent with that pattern, on September 21, 2018, Spackman Media Group deposited

the retainer funds at issue with MSE, which were then placed in MSE’s client trust account. (Spray

Aff. ¶ 3.) Thus, despite Movants’ suggestion that Spackman Media Group is an independent, third-

3
On April 11, 2019, the BVI court froze the assets of the four BVI companies nominally owned
by Spackman’s wife and brother-in-law—Azur Investissement Ltd., Trinity Capital Advisors
Limited, DVG Limited, and GD Enterprise Holdings Ltd—based on Mr. Woo’s showing that they
were acting as Mr. Spackman’s nominees. See Stein Aff. Exs. 2-5 (BVI registered agent
productions); Stein Aff. Ex. 6 (BVI Court Freezing Orders); Han Aff. ¶¶ 35-39, 44-46, 48, 53-55,
58, 64. And, on April 23, 2019, the Singapore court also froze the assets of Mr. Spackman and his
nominees, including the same BVI companies and Spackman’s Partner. (See Stein Aff. Ex. 7
(Singapore Court Freezing Orders).)

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party payor, evidence strongly suggests that Spackman Media Group is another emanation of Mr.

Spackman’s sprawling network of nominees.

IV. Mr. Woo restrains Mr. Spackman’s assets, including the retainer funds.

After noticing entry of this Court’s judgment, Mr. Woo served the restraining notices at

issue and subpoenas on the Movants. (Spray Aff. ¶¶ 5, 9.) Since then, Mr. Woo’s counsel has

been in contact with Movants about this matter, including the status of Movants’ subpoena

responses and the status of the trust account. (Stein Aff. ¶ 14.) In these discussions, Mr. Woo’s

counsel has consistently taken the position that Mr. Woo is entitled to the funds. (Id.)

In response to the subpoenas, Movants produced their retainer agreements with “Mr.

Charles C. Spackman.” (Stein Aff. Ex. 11.) Mr. Spackman agreed to deposit “an initial retainer

of $35,000,” from which the agreement authorized the Movants to deduct fees seven days after

issuing an invoice. (Id. at 3) The agreement further provided that “any unused portion of the

retainer remaining at the end of the representation will be returned to you,” referring to Mr.

Spackman. (Id.)

It is not disputed that the Movants’ invoices issued to Spackman were issued after receipt

of the restraining notices. MSE received a restraining notice on September 27, 2018 (Spray Aff.

¶ 5) and issued an invoice dated October 18, 2018 (Spray Aff. Ex. A). Likewise, EF received a

restraining notice on November 1, 2018 (Spray Aff. ¶ 9) and issued an invoice nearly a month later

on November 29, 2018 (Spray Aff. Ex. C).

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LEGAL ARGUMENT
I. The retainer funds are Mr. Spackman’s property.

The funds deposited in the trust account are property of the judgment debtor, Mr.

Spackman. Under C.P.L.R. § 5201, a “money judgment may be enforced against any property

which could be assigned or transferred, whether it consists of a present or future right or interest

and whether or not it is vested,” which plainly includes the cash balance of an account. While

certain money and property are exempt from restraint under Section 5222, “funds held in escrow

for the purpose of retaining an attorney are not included in [that] statutory list.” See Potter v.

MacLean, 75 A.D.3d 686, 686-67 & n.1 (3d Dep’t 2010) (citing C.P.L.R. 5222(e) and listing

exempt property).

The fact that the funds have been deposited with counsel—rather than held directly by Mr.

Spackman—does not change Mr. Spackman’s property interest in the funds. The C.P.L.R.

specifically recognizes that a judgment debtor’s property may be in the possession of a third party.

See, e.g., C.P.L.R. 5225(b). And numerous courts have recognized that funds deposited in a

retainer account with counsel can be restrained, attached, and garnished. See, e.g., Potter v. 75

A.D.3d at 686-67 & n.1 (affirming restraining notice issued against attorney); M.M. v. T.M., 50

Misc. 3d 565, 578 (Sup. Ct., Monroe Cnty. 2015) (maintaining restraining notice of attorney’s

accounts).

In this case, the funds at issue in Movants’ trust account may be attached because “they are

subject to the judgment debtor’s ‘present or future control,’ or are required to be returned to the

judgment debtor if not used to pay for services rendered.” Potter, 75 A.D.3d at 687. The retention

agreement states that Mr. Spackman controls the retainer: Invoices are provided to Mr. Spackman

so that he has “a ready means of monitoring and controlling the expenses,” and invoiced funds

will be deducted unless he objects within seven days of receipt. (Stein Aff. Ex. 11 at 3.) The

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agreement explains that EF was retained to “render legal services to you,” referring to Mr.

Spackman. (Stein Aff. Ex. 11 at 1.) The scope of the retainer, moreover, refers to the above-

captioned litigation, which states a claim against Mr. Spackman in his personal capacity. (Id.)

Finally, the agreement provides that “any unused portion of the retainer remaining at the end of

the representation will be returned to you,” again addressed to Mr. Spackman. (Stein Aff. Ex. 11

at 3)

And because the invoices against the retainer funds were issued after the restraining notices

were served, Movants have no title to the funds. The agreement clearly states that the retainer

funds were deposited in EF’s “attorney trust account,” that Movants’ fees could only be deducted

seven days after invoicing, and that “any unused portion of the retainer” will be returned to Mr.

Spackman. (Stein Aff. Ex. 11 at 3.) A security retainer deposited in an attorney’s trust account to

be drawn upon invoicing for future services is, by definition, not property of an attorney. See

M.M., 50 Misc.3d at 574-578 (agreement providing return of unused funds created “security

retainer” subject to restraint).

The fact that the invoices here were only issued after the funds in the account had already

been restrained is dispositive. See M.M., 50 Misc.3d at 577 (holding that title transfers to attorney

only after an invoice is issued and “[i]f the restraining notice is served in advance of any billing

by the attorney against those funds, the entire sum of deposited funds is subject to the restraining

notice”). The restraining notice thus means that retainer funds remained the judgment debtor’s

property, and neither possession nor title could have transferred to the Movants.

It is immaterial that the funds were deposited by Spackman Media Group, rather than Mr.

Spackman directly. A security retainer deposited by third parties is subject to restraint under

Section 5222 of the C.P.L.R., as the Appellate Division squarely held in Potter 75 A.D.3d at 687.

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There, the Third Department concluded that because the defendant—not the third-parties who

deposited funds in the law firm account for the benefit of the defendant—had the right to the return

of the retainer fee, and thus the restraining notice applied to the funds. See also Ray v. Jama

Prods., Inc., 74 A.D.2d 845 (2d Dep’t 1980) (restraining notice applied to funds held by third party

but “utilized to satisfy” a judgment debtor’s “debts and expenses”).

It is clear under the retainer agreement in this case that Spackman Media Group did not

retain any property interest in the funds as the third-party payor. However, evidence also strongly

suggests that Spackman Media Group is acting as Spackman’s nominee. Mr. Spackman has an

extensive record of using nominees to hold assets and pay for his personal expenses, and, in this

case, Spackman Media Group, a company named after and founded by Mr. Spackman, has already

paid US $400,761 for Mr. Spackman’s personal legal expenses. (Stein Aff. Ex. 10.) Mr.

Spackman’s use of nominees to pay his legal expenses is consistent with his regular practice of

using nominees to pay for his personal expenses. He has used Richard Lee to pay US $124,932

for his U.S. taxes (Han Aff. ¶ 70.) and $174,731 for his personal legal fees (Han Aff. ¶ 69; Stein

Aff. Ex. 10). Thus, even if New York law gave the depositor a continued interest in the retainer

funds—which it does not—substantial evidence suggests that the depositor, Spackman Media

Group, is merely a nominee for Mr. Spackman and that, therefore, the funds are subject to

enforcement of the judgment.

II. The restraining notice should remain in effect.

Because the retainer funds are property of Mr. Spackman, they should be used to satisfy

the judgment. Movants’ only arguments to the contrary rest on this Court’s discretion to modify

a restraining notice based on equitable considerations. But the equities here support using the

retainer funds to satisfy the pre-existing judgment against Mr. Spackman, which has not been paid

even though it has been nearly twenty years since Mr. Spackman defrauded Mr. Woo. Much like

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the judgment debtor in Potter, Mr. Spackman has “willfully violated his obligation” to Mr. Woo.

See Potter, 75 A.D.3d at 686. Nearly eight years after the Korean courts found Mr. Spackman

liable to Mr. Woo—and months after this Court granted Mr. Woo’s motion for summary

judgment—Mr. Spackman used Spackman Media Group to transfer this money to Movants on

September 21, 2018. (Spray Aff. ¶ 3.)

The Movants made the deliberate choice to continue work on Mr. Spackman’s case for

nearly one month after receiving the restraining notices. (Movants’ Br. at 8 (noting that Movants

chose to “continu[e] to represent Mr. Spackman despite the Restraining Notices”).) And nearly

75% of the fees they ultimately invoiced—US $25,728.10 out of US $34,413.10—was for work

undertaken after the retainer funds were restrained on September 27, 2018. Id. Accordingly, they

assumed the risk (and it was inevitable) that their invoices would not be paid from the retainer

funds, and that they would become a creditor like Mr. Woo.

Movants rely on Pentagon Capital Management to suggest that the equities weigh in favor

of a protective order. However, that case counsels in favor of restraining the retainer funds. The

court in Pentagon did not “exercise its discretion to modify the restraining notice to allow [the

individual defendant] to pay counsel fees” for further appellate review, in part because an

individual defendant may proceed pro se, unlike a corporate defendant that cannot appear but

through counsel. S.E.C. v. Pentagon Capital Mgmt. PLC, No. 08 Civ. 3324(RWS), 2013 WL

5815374, at *7 n.3 (S.D.N.Y. Oct. 29, 2013). In fact, the equitable considerations in Pentagon

favoring a right to counsel decidedly do not apply here given that Mr. Spackman already benefitted

from $575,492 in legal services in this matter from Quinn Emanuel, and he has already received

representation from the Movants and decided not to appeal the Court’s judgment. (Han Aff. ¶ 69;

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Stein Aff. Ex. 10.)4 The restraining notice therefore has no forward looking impact on Mr.

Spackman’s ability to engage attorneys.

Lastly, because evidence strongly shows that Spackman Media Group is being used by Mr.

Spackman as a nominee, the Movants’ suggestion that it would be “unfair to that third party

[Spackman Media Group] to force the funds to be turned over to Mr. Woo” is particularly

misplaced. (Movants’ Br. at 10.) Mr. Spackman has consistently used corporate forms like

Spackman Media Group to serve his own interests and deceive third parties. Indeed, Mr. Woo has

spent the past several months disentangling Mr. Spackman’s use of foreign companies to pay

personal expenses, which has resulted in the freezing orders against Mr. Spackman, Spackman’s

Partner, and the four BVI companies in the BVI and Singapore. (Stein Aff. Exs. 6-7 (Freezing

Orders).) Accordingly, this record shows that Mr. Spackman used Spackman Media Group as a

nominee to deposit the US $35,000 retainer funds into the Movants’ client trust account in this

case.

III. The retainer funds should be turned over to Mr. Woo.

For the same reasons discussed above and because the retainer funds are property of Mr.

Spackman, the Court should require Movants “to pay the money” at issue to Mr. Woo.

C.P.L.R. § 5225; see also id. § 5227. Due to the restraining notice, title to the trust account funds

never transferred to the Movants, and the retainer remains Mr. Spackman’s property. Accordingly,

these funds should be turned over to Mr. Woo toward satisfying this Court’s judgment.

4
Although the court in Pentagon allowed the defendant’s counsel to receive additional fees, it did
so based on “prior agreements” between the judgment debtor with the restraining party to allow
the funds to be released. Pentagon Capital Mgmt. PLC, 2013 WL 5815374, at *7. There is, of
course, no agreement between Mr. Woo and Mr. Spackman to allow the Movants to receive the
funds in this case.

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CONCLUSION
Mr. Woo is empathetic to the Movants’ position because he, too, has suffered first-hand

from Mr. Spackman’s refusal to pay his creditors. However, because the fees on deposit with

Movants’ client trust account were restrained by Mr. Woo as judgment creditor more than a month

before Movants invoiced against the funds, the Motion should be denied and the Cross-Motion

should be granted.

Dated: May 2, 2019
New York, NY
By: /s/ Darryl Stein
Darryl Stein
Darryl.stein@kobrekim.com
John Han
john.han@kobrekim.com.hk
Kobre & Kim LLP
800 Third Avenue
New York, New York 10022
Tel: +1 212 488 1200
Fax: + 1 212 488 1220

Attorneys for Plaintiff/
Judgment Creditor
Sang Cheol Woo

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CERTIFICATION OF WORD COUNT
Pursuant to Commercial Division Rule 17, I hereby certify that the number of words in the
accompanying Memorandum of Law of Sang Cheol Woo in (I) Opposition to Matalon Shweky
Elman PLLC’s and Elman Frieberg PLLC’s Motion for a Protective Order and (II) Support of Mr.
Woo’s Cross-Motion for Garnishment is 3,660, excluding the caption, table of contents, table of
authorities, and signature block, according to the word count by MS Word used to prepare the
document.

Dated: May 2, 2019
New York, NY
By: /s/ Darryl Stein
Darryl Stein

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Case Info

Judge

O. Peter Sherwood Track Judge’s New Case

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Document Filed Date

May 02, 2019

Case Filing Date

May 23, 2017

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Motion-Secondary: Sang Cheol Woo v. Charles C. Spackman

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