On May 05, 2017 a
Motion-Secondary
was filed
involving a dispute between
Freelinc Technologies, Inc.,
and
Chintan Panchal Esq.,
James Christopher Sanborn, Individually And D B A Raisol Advisory Or Raisol Advisory Llc,
Kristin A. Emy, Individually And D B A Raisol Advisory Or Raisol Advisory Llc,
Mitesh P. Lakhani, Individually And D B A Raisol Advisory Or Raisol Advisory Llc,
Raisol Advisory,
Raisol Advisory Llc,
Raisol Capital, Llc,
Raisol Freedom Llc,
Raisol Freedom Manager Llc,
Raisol Llc,
Rastegar Panchal,
for Commercial Division (Breach of fiduciary duty)
in the District Court of New York County.
Preview
FILED: NEW YORK COUNTY CLERK 09/26/2017 05:54 PM INDEX NO. 154220/2017
NYSCEF DOC. NO. 11 RECEIVED NYSCEF: 09/26/2017
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF NEW YORK
--------------------------------------------------------------------------X
FREELINC TECHNOLOGIES, INC.
Plaintiff, Index No. 601411/2015
-against-
RAISOL ADVISORY LLC, RAISOL LLC, RAISOL
CAPITAL, LLC, RAISOL FREEDOM LLC, RAISOL
FREEDOM MANAGER LLC, CHINTAN PANCHAL,
ESQ. and RASTEGAR PANCHAL,
Defendants.
--------------------------------------------------------------------------X
AFFIRMATION OF EVAN W. BOLLA IN SUPPORT OF DEFENDANT RAISOL
ADVISORY LLC’S ORDER TO SHOW CAUSE REQUESTING
ADVANCEMENT OF REASONABLE ATTORNEY FEES AND EXPENSES
I, EVAN W. BOLLA, an attorney duly admitted to practice in the Courts of the
State of New York, affirm under penalty of perjury that:
1. I am a Partner with the law firm of Harris, St. Laurent & Chaudhry, LLP,
(“HSC”), counsel for Raisol Advisory LLC, Raisol LLC, Raisol Capital, LLC, Raisol
Freedom LLC, and Raisol Freedom Manager LLC (collectively the “Raisol Defendants”)
in this action. I am a member in good standing of the New York State Bar, and am fully
familiar with the facts and circumstances set forth below.
2. I respectfully submit this Affirmation in support of Defendant Raisol
Advisory LLC’s Order to Show Cause, requesting advancement of reasonable attorney
fees and expenses.
3. Attached hereto as Exhibit 1 is a true and correct copy of the Amended &
Restated Consulting Agreement, dated March 16, 2016.
4. Attached hereto as Exhibit 2 is a true and correct copy of the March 16,
1
1 of 2
FILED: NEW YORK COUNTY CLERK 09/26/2017 05:54 PM INDEX NO. 154220/2017
NYSCEF DOC. NO. 11 RECEIVED NYSCEF: 09/26/2017
2016 Promissory Note.
5. Attached hereto as Exhibit 3 is a true and correct copy of the Summons with
Notice, filed on or about May 5, 2017.
6. Attached hereto as Exhibit 4 is a true and correct copy of the Supplemental
Summons with Notice, filed on or about August 30, 2017.
7. Attached hereto as Exhibit 5 is a true and correct copy of a letter from L.
Reid Skibell to Charles G. Devine, Jr., dated September 11, 2017.
8. Attached hereto as Exhibit 6 is a true and correct copy of a letter from
Charles G. Devine, Jr. to L. Reid Skibell, dated September 15, 2017.
9. No prior application for this relief has previously been made.
Dated: September 26, 2017
New York, NY
Respectfully submitted,
_________________________________________
HARRIS, ST. LAURENT & CHAUDHRY, LLP
Evan W. Bolla, Esq.
40 Wall Street, 53rd Floor
New York, NY 10006
Attorneys for the Raisol Defendants
2
2 of 2
Document Filed Date
September 26, 2017
Case Filing Date
May 05, 2017
Category
Commercial Division (Breach of fiduciary duty)
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FILED: NEW YORK COUNTY CLERK 09/26/2017 05:54 PM INDEX NO. 154220/2017 NYSCEF DOC. NO. 11 RECEIVED NYSCEF: 09/26/2017 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF NEW YORK --------------------------------------------------------------------------X FREELINC TECHNOLOGIES, INC. Plaintiff, Index No. 601411/2015 -against- RAISOL ADVISORY LLC, RAISOL LLC, RAISOL CAPITAL, LLC, RAISOL FREEDOM LLC, RAISOL FREEDOM MANAGER LLC, CHINTAN PANCHAL, ESQ. and RASTEGAR PANCHAL, Defendants. --------------------------------------------------------------------------X AFFIRMATION OF EVAN W. BOLLA IN SUPPORT OF DEFENDANT RAISOL ADVISORY LLC’S ORDER TO SHOW CAUSE REQUESTING ADVANCEMENT OF REASONABLE ATTORNEY FEES AND EXPENSES I, EVAN W. BOLLA, an attorney duly admitted to practice in the Courts of the State of New York, affirm under penalty of perjury that: 1. I am a Partner with the law firm of Harris, St. Laurent & Chaudhry, LLP, (“HSC”), counsel for Raisol Advisory LLC, Raisol LLC, Raisol Capital, LLC, Raisol Freedom LLC, and Raisol Freedom Manager LLC (collectively the “Raisol Defendants”) in this action. I am a member in good standing of the New York State Bar, and am fully familiar with the facts and circumstances set forth below. 2. I respectfully submit this Affirmation in support of Defendant Raisol Advisory LLC’s Order to Show Cause, requesting advancement of reasonable attorney fees and expenses. 3. Attached hereto as Exhibit 1 is a true and correct copy of the Amended & Restated Consulting Agreement, dated March 16, 2016. 4. Attached hereto as Exhibit 2 is a true and correct copy of the March 16, 1 1 of 2 FILED: NEW YORK COUNTY CLERK 09/26/2017 05:54 PM INDEX NO. 154220/2017 NYSCEF DOC. NO. 11 RECEIVED NYSCEF: 09/26/2017 2016 Promissory Note. 5. Attached hereto as Exhibit 3 is a true and correct copy of the Summons with Notice, filed on or about May 5, 2017. 6. Attached hereto as Exhibit 4 is a true and correct copy of the Supplemental Summons with Notice, filed on or about August 30, 2017. 7. Attached hereto as Exhibit 5 is a true and correct copy of a letter from L. Reid Skibell to Charles G. Devine, Jr., dated September 11, 2017. 8. Attached hereto as Exhibit 6 is a true and correct copy of a letter from Charles G. Devine, Jr. to L. Reid Skibell, dated September 15, 2017. 9. No prior application for this relief has previously been made. Dated: September 26, 2017 New York, NY Respectfully submitted, _________________________________________ HARRIS, ST. LAURENT & CHAUDHRY, LLP Evan W. Bolla, Esq. 40 Wall Street, 53rd Floor New York, NY 10006 Attorneys for the Raisol Defendants 2 2 of 2