On August 23, 2023 a
AFFIDAVIT OR AFFIRMATION IN SUPPORT OF MOTION (Motion #003) - Affirmation of Partha P. Chattoraj in Support of Motion for Admission Pro Hac Vice
was filed
involving a dispute between
Jan S. Wimpfheimer,
Simche Daniel Fulda,
and
East Hudson Capital Llc,
for Special Proceeding - Other - Commercial Division (CPLR ARTICLE 75)
in the District Court of Queens County.
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FILED: QUEENS COUNTY CLERK 09/08/2023 08:04 PM INDEX NO. 717523/2023
NYSCEF DOC. NO. 31 RECEIVED NYSCEF: 09/08/2023
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF QUEENS, COMMERCIAL DIVISION
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JAN S. WIMPFHEIMER and SIMCHE DANIEL Index No. 717523//2023
FULDA, Comm. Div. Part C (Risi, J.)
Petitioners,
-against- AFFIRMATION IN SUPPORT OF
MOTION FOR ADMISSION
EAST HUDSON CAPITAL LLC, PRO HAC VICE
Respondent. Motion Sequence No. 003
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PARTHA P. CHATTORAJ, an attorney duly admitted to practice law in the Courts of the
State of New York, hereby affirms the following to be true under the penalties or perjury,
pursuant to CPLR § 2106(a):
1. I am an attorney at the law firm of Allegaert Berger & Vogel LLP, 111
Broadway, 20th Floor, New York, New York 10006, co-counsel for Respondent EAST
HUDSON CAPITAL LLC, and in that capacity, I have personal knowledge of the facts set forth
herein.
2. I respectfully submit this affirmation in support of Respondent's Motion for
Admission Pro Hac Vice, pursuant to 22 N.Y.C.R.R. § 520.11, for the admission of Juan C.
Zorrilla as counsel pro hac vice to represent Respondent in the above-captioned matter, together
with the undersigned.
3. As evidenced by his Certificate of Good Standing, attached to his sworn affidavit
submitted herewith, Mr. Zorrilla is an active member in good standing of the State of Florida
Bar, having been admitted to practice law in Florida on November 23, 1983.
4. Mr. Zorrilla's affidavit states that he is (i) familiar with and agrees to the rules and
practices of the courts of New York and the New York Rules of Professional Conduct for
1 of 2
FILED: QUEENS COUNTY CLERK 09/08/2023 08:04 PM INDEX NO. 717523/2023
NYSCEF DOC. NO. 31 RECEIVED NYSCEF: 09/08/2023
Attorneys, (ii) shall be subject to the jurisdiction of the courts of the State of New York, (iii)
shall be subject to all disciplinary rules and regulations of the State of New York, and (iv) will
notify this Court immediately of any matter affecting his standing with the Florida Bar.
5. Accompanying this affirmation is a proposed order admitting Mr. Zorrilla pro hac
vice.
WHEREFORE, it is respectfully requested that Respondent’s Motion to admit Juan C.
Zorrilla as counsel pro hac vice to represent Respondent in the above-captioned matter be
granted in its entirety.
Dated: New York, New York
September 8, 2023
/s/ Partha P. Chattoraj
Partha P. Chattoraj
2 of 2
Document Filed Date
September 08, 2023
Case Filing Date
August 23, 2023
Category
Special Proceeding - Other - Commercial Division (CPLR ARTICLE 75)
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FILED: QUEENS COUNTY CLERK 09/08/2023 08:04 PM INDEX NO. 717523/2023 NYSCEF DOC. NO. 31 RECEIVED NYSCEF: 09/08/2023 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF QUEENS, COMMERCIAL DIVISION -----------------------------------------------------------------X JAN S. WIMPFHEIMER and SIMCHE DANIEL Index No. 717523//2023 FULDA, Comm. Div. Part C (Risi, J.) Petitioners, -against- AFFIRMATION IN SUPPORT OF MOTION FOR ADMISSION EAST HUDSON CAPITAL LLC, PRO HAC VICE Respondent. Motion Sequence No. 003 -----------------------------------------------------------------X PARTHA P. CHATTORAJ, an attorney duly admitted to practice law in the Courts of the State of New York, hereby affirms the following to be true under the penalties or perjury, pursuant to CPLR § 2106(a): 1. I am an attorney at the law firm of Allegaert Berger & Vogel LLP, 111 Broadway, 20th Floor, New York, New York 10006, co-counsel for Respondent EAST HUDSON CAPITAL LLC, and in that capacity, I have personal knowledge of the facts set forth herein. 2. I respectfully submit this affirmation in support of Respondent's Motion for Admission Pro Hac Vice, pursuant to 22 N.Y.C.R.R. § 520.11, for the admission of Juan C. Zorrilla as counsel pro hac vice to represent Respondent in the above-captioned matter, together with the undersigned. 3. As evidenced by his Certificate of Good Standing, attached to his sworn affidavit submitted herewith, Mr. Zorrilla is an active member in good standing of the State of Florida Bar, having been admitted to practice law in Florida on November 23, 1983. 4. Mr. Zorrilla's affidavit states that he is (i) familiar with and agrees to the rules and practices of the courts of New York and the New York Rules of Professional Conduct for 1 of 2 FILED: QUEENS COUNTY CLERK 09/08/2023 08:04 PM INDEX NO. 717523/2023 NYSCEF DOC. NO. 31 RECEIVED NYSCEF: 09/08/2023 Attorneys, (ii) shall be subject to the jurisdiction of the courts of the State of New York, (iii) shall be subject to all disciplinary rules and regulations of the State of New York, and (iv) will notify this Court immediately of any matter affecting his standing with the Florida Bar. 5. Accompanying this affirmation is a proposed order admitting Mr. Zorrilla pro hac vice. WHEREFORE, it is respectfully requested that Respondent’s Motion to admit Juan C. Zorrilla as counsel pro hac vice to represent Respondent in the above-captioned matter be granted in its entirety. Dated: New York, New York September 8, 2023 /s/ Partha P. Chattoraj Partha P. Chattoraj 2 of 2