On April 03, 2023 a
Motion-Secondary
was filed
involving a dispute between
Gigi Group, Llc,
Ryan Urban,
and
Hudson Capital Group Ventures, Llc,
for Commercial - Contract
in the District Court of New York County.
Preview
FILED: NEW YORK COUNTY CLERK 08/01/2023 08:51 AM INDEX NO. 651660/2023
NYSCEF DOC. NO. 17 RECEIVED NYSCEF: 08/01/2023
SUPREME COURT OF THE STATE OF NEW YORK
IN AND FOR THE COUNTY OF NEW YORK
RYAN URBAN and GIGI GROUP, LLC,
Index No. 651660/2023 .
Plaintiffs,
~ versus ~
MOTION #001
HUDSON CAPITAL GROUP VENTURES, LLC, Motion to Dismiss
Amended Complaint
Defendant.
AFFIRMATION IN SUPPORT OF
DEFENDANT’S MOTION TO DISMISS
STATE OF NEW YORK )
) ss.
COUNTY OF NEW YORK )
JEREMY MANDEL respectfully submits this Affidavit in Support of the
Motion to Dismiss the Amended Complaint, and respectfully swears under penalties of
perjury as follows to their best of their knowledge:
A. Introduction
1. I am an authorized representative of the Defendant in this matter.
I am over the age of 18 and resident at the City, County and State of New York.
2. I understand that our counsel has filed a Motion to Dismiss the
Amended Complaint. I am informed by my Counsel that this Affidavit in Support of the
Motion to Dismiss is not the forum to address the substantive claims (and Defenses), but
rather is intended to introduce documentary evidence in support of the motion.
Document Id: 368B7500-300D-11EE-96D8-5BE71707C28D
Page 1/4
OnlineNotary.net
1 of 4
FILED: NEW YORK COUNTY CLERK 08/01/2023 08:51 AM INDEX NO. 651660/2023
NYSCEF DOC. NO. 17 RECEIVED NYSCEF: 08/01/2023
3. In particular, the evidence that will be introduced in this Affidavit
will irrefutably evidence that services were provided by the Defendant to Plaintiff Urban,
payments were voluntarily made by Urban to the Defendant on a monthly basis for
almost half-a-year, and that Mr. Urban acknowledged and expressed satisfaction with the
services that the Defendant provided.
4. To the extent that this Honorable Court requires further
documentation about the parties’ relationship, or any other information that may be
necessary in its consideration of this Motion to Dismiss, I am available to provide any
further written or oral testimony that may be necessary or appropriate.
B. Payments Voluntarily made for a half-year
5. Payments were made as follows. Please note that the Exhibits
referred to in Column A (Exhibits A – F) and annexed to this Affidavit are complete,
true and accurate copies of the e-mails that confirm the requests for payments, and receipt
of payment. Each of these Exhibits has been redacted of e-mail addresses and account
information. None of those redactions impact the substantive matters at issue in this
Motion to Dismiss.
Exhibit Date Amount
Exhibit A July 16, 2021 $25,000.00
Exhibit B August 24, 2021 $25,000.00
Exhibit C September 29, 2021 $25,000.00
Exhibit D October 25, 2021 $25,000.00
Document Id: 368B7500-300D-11EE-96D8-5BE71707C28D
Page 2/4
OnlineNotary.net
2 of 4
FILED: NEW YORK COUNTY CLERK 08/01/2023 08:51 AM INDEX NO. 651660/2023
NYSCEF DOC. NO. 17 RECEIVED NYSCEF: 08/01/2023
Exhibit E November 22, 2021 $25,000.00
$25,000.00
Exhibit F December 21, 2021
demanded
6. We also respectfully submit an e-mail chain dated October 14, 2021,
showing that as late as the 4th payment, the Defendant had produced work product for
which Plaintiff Urban “thanked” the Defendant.
7. The e-mail chain referred to above is annexed here as Exhibit G and
is a complete, true and accurate copy of the original. The e-mail chain has been redacted
of e-mail addresses and account information. None of those redactions impact the
substantive matters at issue in this Motion to Dismiss.
Dated: July 31, 2023
RESPECTFULLY SUBMITTED,
By: ___________________________________
Jeremy Mandel
Signed and Sworn before me
this 31th day of July 2023
Please see attached
All Purpose
____________________________ Jurat form
for additional
Notary Events
Document Id: 368B7500-300D-11EE-96D8-5BE71707C28D
Page 3/4
OnlineNotary.net
3 of 4
FILED: NEW YORK COUNTY CLERK 08/01/2023 08:51 AM INDEX NO. 651660/2023
NYSCEF DOC. NO. 17 RECEIVED NYSCEF: 08/01/2023
JURAT ATTACHMENT
A notary public or other officer completing this certificate verifies only the identity of the individual who signed
the document to which this certificate is attached, and not the truthfulness, accuracy, or validity of that
document.
STATE OF Texas }
Tarrant
COUNTY OF _______________________}
The foregoing instrument was subscribed and sworn before me this date of
_____________,
07/31/2023 by _____________________________________________
/IVIQ]2ERHIP
This notarial act was an online notarization.
(Notary Seal)
Notary’s Signature______________________________________________
133645929
Registration No.: _______________________________________________
March 15, 2026
Commission Expiration Date:___________
Document Id: 368B7500-300D-11EE-96D8-5BE71707C28D
Page 4/4
OnlineNotary.net
Powered by TCPDF (www.tcpdf.org)
4 of 4
Document Filed Date
August 01, 2023
Case Filing Date
April 03, 2023
Category
Commercial - Contract
For full print and download access, please subscribe at https://www.trellis.law/.
Preview
FILED: NEW YORK COUNTY CLERK 08/01/2023 08:51 AM INDEX NO. 651660/2023 NYSCEF DOC. NO. 17 RECEIVED NYSCEF: 08/01/2023 SUPREME COURT OF THE STATE OF NEW YORK IN AND FOR THE COUNTY OF NEW YORK RYAN URBAN and GIGI GROUP, LLC, Index No. 651660/2023 . Plaintiffs, ~ versus ~ MOTION #001 HUDSON CAPITAL GROUP VENTURES, LLC, Motion to Dismiss Amended Complaint Defendant. AFFIRMATION IN SUPPORT OF DEFENDANT’S MOTION TO DISMISS STATE OF NEW YORK ) ) ss. COUNTY OF NEW YORK ) JEREMY MANDEL respectfully submits this Affidavit in Support of the Motion to Dismiss the Amended Complaint, and respectfully swears under penalties of perjury as follows to their best of their knowledge: A. Introduction 1. I am an authorized representative of the Defendant in this matter. I am over the age of 18 and resident at the City, County and State of New York. 2. I understand that our counsel has filed a Motion to Dismiss the Amended Complaint. I am informed by my Counsel that this Affidavit in Support of the Motion to Dismiss is not the forum to address the substantive claims (and Defenses), but rather is intended to introduce documentary evidence in support of the motion. Document Id: 368B7500-300D-11EE-96D8-5BE71707C28D Page 1/4 OnlineNotary.net 1 of 4 FILED: NEW YORK COUNTY CLERK 08/01/2023 08:51 AM INDEX NO. 651660/2023 NYSCEF DOC. NO. 17 RECEIVED NYSCEF: 08/01/2023 3. In particular, the evidence that will be introduced in this Affidavit will irrefutably evidence that services were provided by the Defendant to Plaintiff Urban, payments were voluntarily made by Urban to the Defendant on a monthly basis for almost half-a-year, and that Mr. Urban acknowledged and expressed satisfaction with the services that the Defendant provided. 4. To the extent that this Honorable Court requires further documentation about the parties’ relationship, or any other information that may be necessary in its consideration of this Motion to Dismiss, I am available to provide any further written or oral testimony that may be necessary or appropriate. B. Payments Voluntarily made for a half-year 5. Payments were made as follows. Please note that the Exhibits referred to in Column A (Exhibits A – F) and annexed to this Affidavit are complete, true and accurate copies of the e-mails that confirm the requests for payments, and receipt of payment. Each of these Exhibits has been redacted of e-mail addresses and account information. None of those redactions impact the substantive matters at issue in this Motion to Dismiss. Exhibit Date Amount Exhibit A July 16, 2021 $25,000.00 Exhibit B August 24, 2021 $25,000.00 Exhibit C September 29, 2021 $25,000.00 Exhibit D October 25, 2021 $25,000.00 Document Id: 368B7500-300D-11EE-96D8-5BE71707C28D Page 2/4 OnlineNotary.net 2 of 4 FILED: NEW YORK COUNTY CLERK 08/01/2023 08:51 AM INDEX NO. 651660/2023 NYSCEF DOC. NO. 17 RECEIVED NYSCEF: 08/01/2023 Exhibit E November 22, 2021 $25,000.00 $25,000.00 Exhibit F December 21, 2021 demanded 6. We also respectfully submit an e-mail chain dated October 14, 2021, showing that as late as the 4th payment, the Defendant had produced work product for which Plaintiff Urban “thanked” the Defendant. 7. The e-mail chain referred to above is annexed here as Exhibit G and is a complete, true and accurate copy of the original. The e-mail chain has been redacted of e-mail addresses and account information. None of those redactions impact the substantive matters at issue in this Motion to Dismiss. Dated: July 31, 2023 RESPECTFULLY SUBMITTED, By: ___________________________________ Jeremy Mandel Signed and Sworn before me this 31th day of July 2023 Please see attached All Purpose ____________________________ Jurat form for additional Notary Events Document Id: 368B7500-300D-11EE-96D8-5BE71707C28D Page 3/4 OnlineNotary.net 3 of 4 FILED: NEW YORK COUNTY CLERK 08/01/2023 08:51 AM INDEX NO. 651660/2023 NYSCEF DOC. NO. 17 RECEIVED NYSCEF: 08/01/2023 JURAT ATTACHMENT A notary public or other officer completing this certificate verifies only the identity of the individual who signed the document to which this certificate is attached, and not the truthfulness, accuracy, or validity of that document. STATE OF Texas } Tarrant COUNTY OF _______________________} The foregoing instrument was subscribed and sworn before me this date of _____________, 07/31/2023 by _____________________________________________ /IVIQ]2ERHIP This notarial act was an online notarization. (Notary Seal) Notary’s Signature______________________________________________ 133645929 Registration No.: _______________________________________________ March 15, 2026 Commission Expiration Date:___________ Document Id: 368B7500-300D-11EE-96D8-5BE71707C28D Page 4/4 OnlineNotary.net Powered by TCPDF (www.tcpdf.org) 4 of 4