Motion to Quash in Zwirn Jeffrey Vs Solomon, Esq. Marion| Trellis.Law

On April 30, 2020 a Motion,Ex Parte was filed involving a dispute between Jeffrey Zwirn, and Arons & Solomon, Pa, Marion Solomon, Esq., for Professional Malpractice in the District Court of Bergen County.

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NAGEL RICE, LLP
Jay J. Rice, Esq. - 020691977
Michael J. Paragano, Esq. - 032092011
103 Eisenhower Parkway, Suite 103
Roseland, NJ 07068
(973) 618-0400
Attorneys for Plaintiff, Jeffrey Zwirn

SUPERIOR COURT OF NEW JERSEY
JEFFREY ZWIRN, LAW DIVISION - BERGEN COUNTY
DOCKET NO.: BER-L-2574-20
Plaintiff,
Civil Action
-against-
NOTICE OF MOTION TO QUASH
DISCOVERY & COMPEL PARTY
MARION B. SOLOMON, ESQ., ARONS DEPOSITIONS
& SOLOMON, P.A.,
Defendants.

TO William T. McGloin, Esq.
Connell Foley, LLP
56 Livingston Avenue
Roseland, NJ 07068
Attorneys for Defendants, Marion B. Solomon, Esq. & Arons &
Solomon, P.A.

PLEASE TAKE NOTICE that on Friday, March 18, 2022, at 9:00

a.m. in the forenoon or soon thereafter as counsel may be heard,

the undersigned, attorney for Plaintiff herein, shall apply to the

Superior Court of New Jersey, Law Division, Bergen County, Bergen

County Justice Center, 10 Main Street, Hackensack, New Jersey, for

an Order quashing Defendants’ supplemental discovery requests and

ordering party depositions.

PLEASE TAKE FURTHER NOTICE that, in support of this

application, Plaintiff will rely upon the Certification submitted

herewith.
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A proposed form of Order is submitted herewith.

Oral argument is not requested, unless timely opposition is

filed.

The discovery end date in this matter is March 31, 2021.

A trial date has not been set in this matter.

Respectfully submitted,
NAGEL RICE, LLP

By: ay g. Rec
Jay J. Rice
Dated: March 2, 2022
BER-L-002574-20 03/02/2022 4:04:00 PM Pg 1 of 2 Trans ID: LCV2022875941

NAGEL RICE, LLP
Jay J. Rice, Esq. - 020691977
Michael J. Paragano, Esq. - 032092011
103 Eisenhower Parkway, Suite 103
Roseland, NJ 07068
(973) 618-0400
Attorneys for Plaintiff, Jeffrey Zwirn

JEFFREY ZWIRN,
SUPERIOR COURT OF NEW JERSEY
Plaintiff, BERGEN COUNTY: LAW DIVISION
DOCKET NO. BER-L-2574-20
-against-
ORDER

MARION B. SOLOMON, ESQ., ARONS
& SOLOMON, P.A.,
Defendants.

THIS MATTER being opened to the Court by Plaintiff, Jeffrey

Zwirn by and through his attorneys, Nagel Rice, LLP by way of

motion to quash Defendants’ supplemental request for production

and documents and to compel party depositions, and for good cause

shown:

IT IS on this day of March 2022,

ORDERED as follows:

1 Defendants’ supplemental documents requests nos. 22, 23,

24, 25, 28, 31, 32, 33, 34, 35, 39, 40, 41, 42, 43, 45, 46, 47,
48, 49, 61, 62, 63, 65, 57, 68 and 70 are hereby quashed and

Plaintiff shall have no obligation to produce documents relating

to same;
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2 Fact depositions of the parties shall take place on or

before April 15, 2022 in the following order:

Marion Solomon

Jennifer Bretz

Jeffrey Zwirn

Mitchell Arons

The parties shall agree upon the deposition dates within

five (5) business days from the date of this Order.

4 The Court shall retain jurisdiction to bar any of the

aforesaid witnesses from testifying at trial if a witness, without

just cause, refuses to appear for depositions within the time frame

set forth above.

5 A copy of this Order shall be deemed served on all

parties upon electronic filing.

Honorable Rachelle L. Harz
BER-L-002574-20 03/02/2022 4:04:00 PM Pg 1 of 41 Trans ID: LCV2022875941

NAGEL RICE, LLP
Jay J. Rice, Esq. - 020691977
Michael J. Paragano, Esq. - 032092011
103 Eisenhower Parkway, Suite 103
Roseland, NJ 07068
(973) 618-0400
Attorneys for Plaintiff, Jeffrey Zwirn

SUPERIOR COURT OF NEW JERSEY
JEFFREY ZWIRN, LAW DIVISION - BERGEN COUNTY
DOCKET NO.: BER-L-2574-20
Plaintiff,
Civil Action
-against-
CERTIFICATION OF COUNSEL

MARION B. SOLOMON, ESQ., ARONS
& SOLOMON, P.A.,
Defendants.

I, JAY J. RICE, hereby certifies and states as follows:

1 I am an attorney at law in the State of New Jersey, and

a partner with the law firm of Nagel Rice, LLP, attorneys for

Plaintiff, and as such am fully familiar with the facts of this

case. This certification is in support of Plaintiff’s Motion for

an order quashing Defendants’ supplemental discovery requests and

ordering party depositions.

2 This matter involves Plaintiff's claims for legal

malpractice against Defendants, Marion B. Solomon, Esq. and Arons

& Solomon, P.A. (hereinafter “Defendants” ) for their

representation during Plaintiff’s divorce litigation.

3 Plaintiff’s present motion seeks intervention from the

Court based upon a history of delay by the Defendants over the
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last eighteen (18) months.

4 More specifically, throughout this litigation,

Plaintiff’s right to depose Defendants has been impeded, including

through violations of court orders issued by Your Honor. Defendants

now have requested voluminous discovery that include requests that

are in violation of the attorney/client privilege and work product

doctrine, that are overly burdensome, that are not calculated to

lead to any discoverable evidence, that are irrelevant, harassing

and are part of the defendants' fishing expedition strategy.

Defendants now refuse to produce their witnesses for depositions

until the latest discovery demands are met.

5 By way of background, Plaintiff filed suit against

Defendants in or about April 30, 2020. In brief, the complaint

is a legal malpractice claim against defendants who represented

plaintiff in an underlying matrimonial action. Plaintiff alleges

that Defendants were directed to accept a settlement proposal

offered by counsel for Plaintiff’s wife in or about August 30,

2018. Defendant failed to accept the offer, but rather submitted

a draft marital settlement agreement ("MSA") that contained

material conditions not included in the wife's offer. The trial

court determined that, because of these added conditions by the

defendants, no settlement was reached. Months later and with new

counsel, Plaintiff entered into a MSA that was and is

substantially more expensive. Plaintiff’s damages include the
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difference between the earlier offer by the wife and the final

settlement terms.

6 Defendants filed their answer and counterclaim on or

about June 5, 2020.

7 Thereafter, Plaintiff submitted written discovery

requests on July 9, 2020 and October 13, 2020. Plaintiff was

forced to advise Defendants in writing of overdue responses on

October 2, 2020, November 9, 2020 and December 7, 2020. Deficiency

letters were sent on March 10, 2021 and April 28, 2021.

8 Defendants served discovery requests on December 22

2020, which were responded to within 60 days and have been

subsequently supplemented in March and May 2021.

9 Plaintiff submitted deposition notices for the

depositions of Defendants on September 25, 2020, November 4, 2020,

January 22, 2021 and again on June 2, 2021.

10. Plaintiff has therefore been seeking the deposition of

Defendants for almost eighteen (18) months. In the process and

with the aid of the Court, a court order was agreed to setting

forth that these depositions take place before September 15, 2021.

Defendants then ignored the terms of the order.

11. In addition, Plaintiff has had to file four separate

motions to compel Defendants to comply with discovery obligations.

12. In or about November 30, 2021, some eighteen (18) months

after issue was joined, Defendants served 72 supplemental document
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requests, as well as new subpoenas served on Plaintiff's

Matrimonial counsel who succeeded defendants (Erin Thompson, Esq.

and Bastarrika & Sota, Esqs.).

13. More recently as counsel was resolving these November

2021 discovery requests, defendants served three new subpoenas —

one on the attorney who represented Plaintiff in his appeal of

the trial court order denying the existence of the agreed-upon

settlement. Subpoenas were also served on Plaintiff's economic

expert in the matrimonial case and the attorney for Plaintiff’s

wife. Plaintiff has subsequently moved to quash the former two

subpoenas as violation of the attorney/client privilege and work

product doctrine, which is pending before Your Honor.

14. Disputes as to the subpoenas served by Defendants upon

Erin Thompson and Bastarrika Soto, Esqs., have been resolved by

the parties. Plaintiff has agreed to waive the attorney/client

privilege for that time period up to and including the date the

underlying MSA was agreed to and placed on the record. For the

time period subsequent to this date, if Plaintiff seeks to assert

attorney/client privilege, he will do so for only those documents

that are not relevant and would not lead to relevant knowledge

and will provide a privilege log on same. Attached hereto as

Exhibit A is a true and accurate copy of Plaintiff’s counsel’s

letter to subpoena parties.

15. Therefore, at issue for the court's determination is
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Defendants’ unresolved document demands and Plaintiff’s response

to same. Attached hereto as Exhibit B & Exhibit C are Defendants’

Supplemental Discovery Requests and Plaintiff’s counsel’s letter

dated February 10, 2022.

16. As more specifically set forth in Plaintiff’s counsel’s

letter of February 10, 2022, of the seventy-two (72) supplemental

requests, Plaintiff has no documentation in regard to twenty (20)

of the requests and eleven (11) of the requests have been

voluntarily withdrawn. Documents in regard to fourteen (14)
requests have been or will be produced.

17. Therefore, Plaintiff has declined to produce twenty-

seven (27) requests, which fall into three categories.

18. First, request no. 61 seeks copies of all retainer

agreements for all matters in which Plaintiff has testified as

an expert (his business capacity) in the past five years,

including all billing payments, copies of expert reports and

transcript of testimony of Mr. Zwirn testifying here as an

expert. Such a document request could be considered reasonable

if Mr. Zwirn was testifying as an expert. Mr. Zwirn is in this

case, however, is a fact witness. Defendants have failed to offer

any rationale or justification for the production of such

documents. Moreover, over the past five (5) years, Mr. Zwirn has

been retained as an expert in 117 cases, making a response to

this request clearly burdensome and oppressive and would involve
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Matters subject to confidentiality agreements.

19. Second, the most significant issue in regard to the

balance of the requests are for a slew of financial records.

Initially, it should be noted that Plaintiff has produced all

financial records provided to his successor counsel, Erin

Thompson, that would have been in counsel's possession when the

MSA was put on the record.

20. Third, Plaintiff has produced the portion of his federal

tax returns for 2018, 2019 and 2020 that show that his income has

not been reduced such that he could not seek a modification and

reduction of his alimony obligations.

21. These are the two areas where Mr. Zwirn's financial

history is relevant to the issues in this case. This production

includes all the financial documentation required under New Jersey

Rules for submission of a case information statement.

22. Defendants have made the following requests seeking

financial information for the time period 2014 to the present from

all companies, Mr. Zwirn has ownership in. Specifically,

defendants seek as follows:

Financial statements (No. 22);
Supplemental information and internal management
reports (No. 22);
All interim financial statements (No. 23);
Supplemental information and internal management
reports (No. 23);
Federal and state tax returns, including all schedules
attached (No. 24);
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Electronic copies of Quick Books, general ledger
databases — includes profit and loss statements and
balance sheets (No. 25);
All budgets forecasting projections, business plans
and supplemental schedules (No. 28);
All real estate, business, equipment and inventory
appraisals and consulting reports (No. 31);
Details on all buy-in or buy-out transactions (No.
32);
10 All offers to buy, including efforts to merge or
consolidate (No. 33);
11 All offers to buy another entity (No. 34);
12 All pension and profit-sharing plans, copies of
trustee reports (No. 35);
13 Compensation for each of the top 5 compensated
individuals (No. 39);
14 Copies of plaintiffs federal and state tax returns
(returns prior to the settlement being put on record
were produced) (No 40);
15 All documents supplied to any accountant or tax
preparer (No. 41):
16 Copies of all documents regarding any audit of
plaintiffs tax returns (No. 42);
17 Copies of all personal financial statements (No. 43);
18 Copies of all documents relating to business expenses,
including telephone, credit card, etc. (No. 45);
19 All contracts, agreements or purchase orders entered
by plaintiff (No. 46);
20 All documents concerning any contracts, agreements or
purchase orders negotiated (No. 47);
21 All contracts, agreements or purchase orders (No. 48);
22 All documents concerning any agreements or purchase
orders (No. 49)
23 Copies of documents regarding all real estate in which
plaintiff has an interest (No. 62);
24 Copies of all applications by plaintiff for credit,
including mortgage applications, lease applications,
car leases, credit cards (No. 63);
25 Copies of all credit cards which plaintiff has held or
had use (No. 65);
26 True statements of all bank, stock, money market or
other investment accounts (No. 67);
27 All documents concerning any application plaintiff
made to lease a vehicle (No. 68).
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23. There can be no question that the above documents taken

together are burdensome, oppressive and simply not relevant to the

issues in this action.

24. It is significant that, pursuant to R. 5:5-2, parties to

a matrimonial action are obligated to comply with the information

required by the case information statement that requires only the

production of one year of filed tax returns (this has already been

produced to Defendants) .

25. As all the financial documents relied upon or in the

possession of Plaintiff’s successor marital attorney have and will

be produced, this is no basis for the outrageous requests seeking

literally five (5) years of every business documents Plaintiff may

have. It is, at best, a fishing expedition that the Court should

not allow.

26. Lastly, in regard to Request No. 70, Defendants seek to

obtain records of Plaintiff’s payments to or for Plaintiff's

daughter Anna. Anna is not a minor and there is no obligation under

the MSA to provide for her. Thus, any payments made by Plaintiff

to his daughter have no relevance to the pending action.

27. Based upon the above, it is therefore respectfully

requested that the Court enter an order quashing Defendant’s

supplemental discovery requests as detailed above and compelling

the depositions of all parties to be completed by April 15, 2022.

I certify that the foregoing statements made by me are true.
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I am aware that if any of the foregoing statements made by me are

willfully false, I am subject to punishment.

Jay J. Rice
Dated: March 2, 2022
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EXHIBIT A
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NAGEL RICE, LLP
COUNSELLORS AT LAW
BRUCE H. NAGEL 103 EISENHOWER PARKWAY ANOREW |. PEPPER
VAY J. RICE SUITE 103 MICHAEL J, PARAGANOS:
ROBERT H, SOLOMON ROSELAND, NEW JERSEY 07068 SCOTT M. JACOBSON?
OIANE E. BAMMGNS? (973) 618-0400 EMMA A. MCELLIGOTT
LORI. MAYER? FAX: (973) G18-9194
RANDEE M, MATLOFF SENIOR COUNSEL
WWW.NAGELRICE.COM 5.M. CHRIS FRANZBLALS
ANDREW L. @’G@NNOR
GREG M. KOHN? “CERTIFIED OY THE SUPREME COURT OF
SUSAN F. CONNORS 230 PARK AVENUE NEW JERSEY AB A cIve TIAL ATTORNEY
BRADLEY b, RICE NEW YORK, NY 19168 OMEMBER OF Wy 6 NY BARS
tala) s#i-sa86 ONCHBENOF NJ, NY € DE BARE
HARRY A. MARGOLIS PLEASE REPLY TO.
tez8-2008 ROSELANO OFFICE

February 9, 2022

Wia Email: Evin @thonpsondivorcelaw.com)
Erin L. Thompson, Esq.
Law Office of Erin L, Thompson, LLC
205 US-46 #4
Totowa, NJ 07512

Re: Zwirn v. Arons & Solomon, P.A., et al.
Docket No,: BER-L-2574-20

Dear Ms, Thompson:

Please be advised that the undersigned represents plaintiff, Jeffrey Zwirn, in regard to the
above matter.

Recently, counsel for defendants served a subpoena duces teoum upon you for the
production of documents (see annexed). Our office, thereafter, filed a motion to quash.

My adversary and I have come to a resolution of the pending motion to quash as follows:

1. To the extent you have documents responsive to the subpoena, you are to produce
same directly to me,

My client has agreed to waive the attorney client privilege for any and all
documentation up to and including the settlement of the matrimonial action put on the
record.

For documents that were created or obtained after the date the settlement was put on.
the record, my client is reserving the attorney client privilege for documents that refer
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to or discuss the present legal malpractice action. I will create a privilege log for such
documents.

Please advise if you will be able to produce the documents by Friday, February 11, 2022,

Piease contact me if you have any questions.

Very truly yours,

AVE

JAb RICE
ce: William T. McGloin, Esq.
BER-L-002574-20 03/02/2022 4:04:00 PM Pg 13 of 41 Trans ID: LCV2022875941

NAGEL RICE, LLP
COUNSELLORS AT LAW
BRUCE 4. NAGELt 103 EISENHOWER PARKWAY ANDREW I, PEPPER,
JAY J. RICE SUITE 103 MICHAEL J, PARAGANO®
ROBERT H. SOLOMON ROSELAND, NEW JERSEY 07068 SCOTT M. JACOBSON?
DIANE E. SAMMONS? 1973) GIB-0400 EMMA A. MCELLIGOTT.
LOR |. MAYER® FAX: (973) 618-9194
RANDEE M. MATLOFF SENIOR COUNSEL
WWW.NAGELRICE.COM 5.M, CHRIS FRANZBLAUS
ANDREW 1. o°cONNOR
GREG M. KOHN? Scanvinico oY THe GUPREME GOURT OF
SUSAN F. CONNORS, 290 PARK AVENUE, NEW seRaey ABA cIve TRIAL ATTORNEY
RADLEY {1 ICES NEW YORK, NY Ioi6o, DHEMORN OF NU & NY ARS
(212) 861-1465, ODIEMBER OF Ni, HY & Be BANS
HARRY A, MARGOLIS PLEASE REPLY TO
i928-2002 ROSELAND OFFICE

February 9, 2022

Wia Email: Sbastarrika@bsgslaw.com)
Jose I. Bastarrika, Esq.
Bastarrika Soto Gonzalez Somohano LLP
3 Garret Mountain Plaza, Suite 302
Woodland Park, NJ 07424

Re: Zwirn y. Arons & Solomon, P.A., et al.
Docket No.: BER-L-2574-20

Dear Mr, Bastarrika:

Please be advised that the undersigned represents plaintiff, Jeffrey Zwirn, in regard to the
above matter.

Recently, counsel for defendants served a subpoena duces tecum upon you for the
production of documents (see annexed). Our office, thereafter, filed a motion to quash.

My adversary and I have come to a resolution of the pending motion to quash as follows:

1 To the extent you have documents responsive to the subpoena, you are to produce
same directly to me,

My client has agreed to waive the attomey olient privilege for any and all
documentation up to and including the settlement of the matrimonial action put on the
record.

For documents that were created or obtained after the date the settlement was put on
the record, my client is reserving the attorney client privilege for documents that refer
to or discuss the present legal malpractice action. I will create a privilege log for such.
documents.
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Please advise if you will be able to produce the documents by February 11, 2022.

Please contact me if you have any questions.

ms,

Ai “truly yours,

VA
JAN]. CE
ce; William T, McGloin, Esq.
Ww
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William T, McGloin 030731991
CONNELL FOLEY LLP
56 Livingston Avenue
Roseland, NJ 07068
(973) 535-0500
Attorneys for Defendants, Marion B. Solomon, Esq. and Arons & Solomon, P.A.

SUPERIOR COURT OF NEW JERSEY
JEFFREY ZWIRN, LAW DIVISION: BERGEN COUNTY
DOCKET NO. L-2574-20
Plaintiff,
vi Civil Action

MARION B, SOLOMON, ESQ., ARONS & SUBPOENA DUCES TECUM
SOLOMON, P.A.,

Defendants,

THE STATE OF NEW JERSEY:

TO: Erin L. Thompson, Esq,
The Law Office of Erin L, Thompson, LLC
205 US-46 #4
Totowa, NJ 07512

YOU ARE HEREBY COMMANDED to attend and give testimony before a certified

shorthand reporter on December 20, 2021 at 10:00 a.m, at the offices of Connell Foley LLP,

located at 56 Livingston Avenue, Roseland, NJ 07068 in connection with the above-entitled action

and that you have and bring with you and produce at the same time and place the following:

SEE ATTACHED RIDER

*In lieu of an appearance, pursuant to New Jersey Court Rule 4:14-7(c), we will

ecept certified copies of your records provided that you advise this office in advance of the

scheduled deposition that you will release the requested information. The certification must

be in the form attached,

6228055-1
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The subpoenaed evidence shall not be produced or released until the day specified herein

for your deposition. If you are notified that a Motion to Quash the Subpoena has been filed, the

subpoenaed evidence shall not be produced or released until ordered to do so by the Court or the

release is consented to by all to this action,

Failure to appear or comply according to the command of this Subpoena will subject you

to a penalty, damages in a Civil Suit and punishment for contempt of Court,

Dated: December 9, 2021

Ist Weéltiawe 7. WeGloin /s/Michelle M. Smith
William T. McGloin, Esq. Michelle M. Smith, Clerk
CONNELL FOLEY LLP
Attorneys for Defendants,
Marion B, Solomon, Esq. and
Arons & Solomon, PA.

6228055-1
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RIDER

All documents, including, but not limited to, any written, graphic, electronic or recorded
matter, and all non-identical all non-identical copies and drafts thereof (whether different
from the original because of handwritten notes, underlining or otherwise) including,
without limitation, correspondence, contracts, agreements, memoranda, e-mails, texts,
telexes (faxes), notes, recordings of telephone or other forms of oral communications,
cables, appointment books, diaries, calendars, journals, analyses, reports, studies,
summaries, charts, graphs, work papers, and data of whatever other nature or in any other
retrievable form which is in the possession, custody or control of the subpoenaed party
together with each addendum, attachment, modification, correction, amendment thereto,
marginal notation or enclosure therewith (hercinafler “Documents”) referring or relating
to services provided by Erin Thompson, Esq. (hereinafter “You”) to Jeffrey Zwirn while
at Your current firm or any prior firm.

All Documents exchanged between You and Jeffrey Zwirn that predate Your retention.

3, Al! Documents created by You regarding Jeffrey Zwirn that predate Your retention.
Any Documents prepared in connection with any investigation conducted by You or
anyone acting on Your behalf regarding Your representation of Jeffrey Zwirn.

All Documents exchanged between You and Jeffrey Zwirn regarding the Jeffrey Zwirn
vs. Debra Zwirn litigation including any post judgment motions, applications or other
litigation (hereinafter, collectively the “Divorce matter”),

All emails and text messages between You and Jefftey Zwirn regarding the Divorce
matter,

7 All agreements between You and Jeffrey Zwirn regarding the Divorce matter,

All statements, written or recorded, in Your possession or contro! regarding the Divorce
matter,

All discovery demands You served in the Divorce matter and all responses received.
10. All discovery demands You received in the Divorce matter and all responses provided,

ll Transcripts from any depositions You participated in with regard to the Divorce matter,

12. Transcripts from any Court appearance You participated in with regard to the Divorce
matter,

13 All documents evidencing communications between You and Debra Zwirn’s counsel in
the Divorce matter.

6228055-1
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14, Any and all handwritten notes and/or transcriptions of handwritten notes created by You
in connection with any of Your oral communications and/or meetings with Jeffrey Zwirn
with regard to the Divorce matter.

15. The reports of any and all experts who reviewed any aspect of the Divorce matter at Your
request,

16, All Documents submitted by You to any expert in the Divorce matter,

17. All Documents relating to any communication with the Court in the Divorce matter from
November 2019 to present, including, but not limited to, correspondence, pleadings,
motions, exhibits, certifications, orders, etc.

18. All Documents referring or relating to the settlement of the Divorce matter.

19. All Documents referring or relating to the negotiations with regard to the resolution of or
attempt at resolution of the Divorce matter.

20, All Documents referring or relating to the mediation of any aspect of the Divorce matter.

21, True and accurate copies of any and all documents memorializing, referring to, regarding
or relating to any and all communications between You and Jeffrey Zwirn.

22, True and accurate copies in Your possession or control of any and all correspondence,
emails or other communications between the parties in the Divorce matter between
November 2019 to present.

23. All documents in Your possession of control regarding the financial wishes of Jeffrey
Zwirn between November 2019 and present.

24, All documents in Your possession or contro! regarding any risks about which You
advised Jeffrey Zwirn regarding the Divorce matter,

25. True and accurate copies of any and all documents provided by Jeffrey Zwirn to You for
the purpose of You performing any and all legal work,

26, A complete copy of your file regarding the Divorce matter,

27, All invoices You submitted to Jeffrey Zwir

Case Info

Judge

HARZ, RACHELLE Track Judge’s New Case

Case No.

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Document Filed Date

March 02, 2022

Case Filing Date

April 30, 2020

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Motion,Ex Parte: Zwirn Jeffrey Vs Solomon, Esq. Marion

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