Exhibit,Appendix: Marcus Abrams, Clearwater Ventures, Inc., Lisa Abrams, Lisa Abrams in her capacity as Trustee for the Lisa Marie Abrams Revocable Trust v. Russell Abrams, Russellcar Inversora, S.A., Crosstax, S.A., Taxcorp, S.A., Carcorp, S.A., Russellcar S.R.L., Aracar Group Holdings Corp., Aracar Financiera, S.A., Aracar Servicios, S.A., Aracar Group Spv I Llc, Aracar Group Spv Ii Llc

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                                FILED: NEW YORK COUNTY CLERK 02/25/2023 06:16 AM                                                                   INDEX NO. 654992/2022
NYSCEF DOC. NO. 51                                                                                       RECEIVED NYSCEF: 02/25/2023




                                            IN ARBITRATION BEFORE THE
                                         AMERICAN ARBITRATION ASSOCIATION

         ________________________________________
         Marcus Abrams Clearwater Ventures, Inc.,
         Lisa Abrams, and the Lisa Marie Abrams
         Revocable Trust,                                                   AAA Case No. 01-20-0007-3684

                                        Claimants,
                                                                            AFFIRMATION
         -against-                                                          JAMES R. SERRITELLA

         Russell Abrams, Sandra Abrams, and
         “RussellCar and its related entities” defined in
         The parties’ agreement as “Issuer”,

                           Respondents.
         ________________________________________

                     James R. Serritella, an attorney duly licensed to practice law in the State of New York,

         affirms the following facts under penalty of perjury:

                     1.       I am a partner at the law firm Kim & Serritella LLP, attorneys for Claimants Marcus

         Abrams and Lisa Abrams as Trustee for the Lisa Marie Abrams Revocable Trust.

                     2.       I submit this affirmation in support of Claimants’ dispositive motion, dated March

         18, 2022 (the “Motion”).

                     3.       Included as Exhibit 1 7 is a true and correct copy of the Order signed by the

         Honorable Joel M. Cohen, dated December 14, 2021, in Abrams, et al. v. Abrams, et al., Index No.

         658845/2021 (Sup. Ct. N.Y. County) (the “Attachment Proceeding”).

                     4.       Included as Exhibit 8 is a true and correct copy of the Order signed by the

         Honorable Joel M. Cohen, dated January 14, 2022, in the Attachment Proceeding.

                     5.       Included as Exhibit 9 is a true and correct copy of the transcript from the December

         11, 2021 hearing in the Attachment Proceeding.


          1
              “Exhibit” as used herein refers to the exhibits on the master List if Exhibits Submitted in support of the Motion.

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FILED: NEW YORK COUNTY CLERK 02/25/2023 06:16 AM                                                INDEX NO. 654992/2022
NYSCEF DOC. NO. 51                                                                     RECEIVED NYSCEF: 02/25/2023




                 6.      Included as Exhibit 10 is a true and correct copy of the transcript from the January

          13, 2022 hearing in the Attachment Proceeding.

                 7.     Included as Exhibit 30 is a true and correct copy of the transcript of the September

          22, 2021 deposition of Russell Abrams in this proceeding.

                 8.     Included as Exhibit 37 is the complaint filed in GlobeOp Financial Services, et al.

          v. Abrams, et al., Index No. 650241/2015 (Sup. Ct. N.Y. County).

                 9.     Included as Exhibit 38 is the Affirmation of Marc Susswein ¶ 2-3, Docket No. 88,

          Ballard v. Titan Capital Group III, L.P., Index No. 653005/2012 (Sup. Ct. N.Y. County)



          Dated: New York, New York                                   /s/ James R. Serritella
                 March 18, 2022                                         James R. Serritella




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