On May 30, 2023 a
Exhibit,Appendix
was filed
involving a dispute between
Hussein Badr,
and
Adt Security Services Inc.,
Gelco Fleet Trust,
Jean Bouloute,
for Torts - Motor Vehicle
in the District Court of Kings County.
Preview
FILED: KINGS COUNTY CLERK 10/23/2023 05:20 PM INDEX NO. 515722/2023
..
NYSCEF DOC. NO. 36 RECEIVED NYSCEF: 10/23/2023
..
EXHIBIT A
FILED: KINGS COUNTY CLERK 10/23/2023 05:20 PM INDEX NO. 515722/2023
NYSCEF DOC. NO. 36 RECEIVED NYSCEF: 10/23/2023
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF KINGS
HUSSEIN BADR,
Plaintiffs), A F F ID A V IT O F
D A N IE L R . M IT C H E L L
-against-
Index No. 515722/2023
JEAN BOULOUTE, ADT SECURITY SERVICES
INC. and GELCO FLEET TRUST,jihgfedcbaZYXWVUTSRQPONMLKJIHGFEDCBA
Defendant(s).
STATE OF MINNESOTA )
) ss.
COUNTY OF HENNEPIN )
I, Daniel R. Mitchell, being of full age and duly sworn, depose and say that:
1. I make this Affidavit in support of a motion to admit me to appear and participate
in this action ponmlkjihgfedcbaZYXWVUTSRQPONMLKJIHGFEDCBA
pro hac vice for the purpose of assisting in the defense of this action.
2. I am an attorney in the Donna Law Firm, P.C., located at 7601 France Avenue vutsrqponmlkjih
South, Suite 350, Minneapolis, Minnesota 55435.
3. My practice is largely focused on civil litigation, including auto liability litigation,
as national counsel to ADT, LLC (Incorrectly named as ADT Security Services, Inc.).
4. I am a member in good standing in the jurisdiction in which I am admitted to
practice. I was admitted to the practice of law in the State of Minnesota in 2003 and have been a
member in good standing since that time.
5. I have never been the subject of an investigation in any disciplinary proceeding nor
have I ever been censured, suspended or disbarred.
FILED: KINGS COUNTY CLERK 10/23/2023 05:20 PM INDEX NO. 515722/2023
NYSCEF DOC. NO. 36 RECEIVED NYSCEF: 10/23/2023
.
6. I am working on this case in conjunction with the law firm of GOLDBERG
SEGALLA LLP, and Abraham D. Leybengrub, an attorney admitted to practice in the State of
New York.
7. Mr. Leybengrub is a member in good standing of the New York State Bar and
represents Defendants JEAN BOULOUTE ADT, LLC (Incorrectly name as ADT Security
Services, Inc.), GELCO FLEET TRUST, in the instant matter.
8. Mr. Leybengrub is and shall continue to be attorney of record in this matter.
9. If admitted, I shall be familiar with and shall comply with the standards of
professional conduct imposed upon members of the New York bar, including the rules of court
governing the conduct of attorneys and the Rules of Professional Conduct.
10. If admitted, I shall be subject to the jurisdiction of the courts of this State with
respect to any acts occurring during the course of the attorney's participation in the matter.
11. If admitted, I will abide by the Rules of this Court and will be available for all Court
conferences, motions and trial dates.
Dýrrefl•. Mitchell
Sworn to and subscribed before me
this2 p_%ay of September, 2023
.p'
JACQUELINE MASSE
Nota [ Notary Public
Minnesota
My Commission Expires
* , j..
Jan 31, 2025
-2-
Document Filed Date
October 23, 2023
Case Filing Date
May 30, 2023
Category
Torts - Motor Vehicle
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Preview
FILED: KINGS COUNTY CLERK 10/23/2023 05:20 PM INDEX NO. 515722/2023 .. NYSCEF DOC. NO. 36 RECEIVED NYSCEF: 10/23/2023 .. EXHIBIT A FILED: KINGS COUNTY CLERK 10/23/2023 05:20 PM INDEX NO. 515722/2023 NYSCEF DOC. NO. 36 RECEIVED NYSCEF: 10/23/2023 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF KINGS HUSSEIN BADR, Plaintiffs), A F F ID A V IT O F D A N IE L R . M IT C H E L L -against- Index No. 515722/2023 JEAN BOULOUTE, ADT SECURITY SERVICES INC. and GELCO FLEET TRUST,jihgfedcbaZYXWVUTSRQPONMLKJIHGFEDCBA Defendant(s). STATE OF MINNESOTA ) ) ss. COUNTY OF HENNEPIN ) I, Daniel R. Mitchell, being of full age and duly sworn, depose and say that: 1. I make this Affidavit in support of a motion to admit me to appear and participate in this action ponmlkjihgfedcbaZYXWVUTSRQPONMLKJIHGFEDCBA pro hac vice for the purpose of assisting in the defense of this action. 2. I am an attorney in the Donna Law Firm, P.C., located at 7601 France Avenue vutsrqponmlkjih South, Suite 350, Minneapolis, Minnesota 55435. 3. My practice is largely focused on civil litigation, including auto liability litigation, as national counsel to ADT, LLC (Incorrectly named as ADT Security Services, Inc.). 4. I am a member in good standing in the jurisdiction in which I am admitted to practice. I was admitted to the practice of law in the State of Minnesota in 2003 and have been a member in good standing since that time. 5. I have never been the subject of an investigation in any disciplinary proceeding nor have I ever been censured, suspended or disbarred. FILED: KINGS COUNTY CLERK 10/23/2023 05:20 PM INDEX NO. 515722/2023 NYSCEF DOC. NO. 36 RECEIVED NYSCEF: 10/23/2023 . 6. I am working on this case in conjunction with the law firm of GOLDBERG SEGALLA LLP, and Abraham D. Leybengrub, an attorney admitted to practice in the State of New York. 7. Mr. Leybengrub is a member in good standing of the New York State Bar and represents Defendants JEAN BOULOUTE ADT, LLC (Incorrectly name as ADT Security Services, Inc.), GELCO FLEET TRUST, in the instant matter. 8. Mr. Leybengrub is and shall continue to be attorney of record in this matter. 9. If admitted, I shall be familiar with and shall comply with the standards of professional conduct imposed upon members of the New York bar, including the rules of court governing the conduct of attorneys and the Rules of Professional Conduct. 10. If admitted, I shall be subject to the jurisdiction of the courts of this State with respect to any acts occurring during the course of the attorney's participation in the matter. 11. If admitted, I will abide by the Rules of this Court and will be available for all Court conferences, motions and trial dates. Dýrrefl•. Mitchell Sworn to and subscribed before me this2 p_%ay of September, 2023 .p' JACQUELINE MASSE Nota [ Notary Public Minnesota My Commission Expires * , j.. Jan 31, 2025 -2-